For clarity, Dare Coaching may use both data controller and data processor for your personal data under certain circumstances. Please be advised that this policy is subject to change, so please check our website on a regular basis for any further changes.
It is important that you read this notice, together with any other Privacy Notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we use such data.
Data Protection Principles
We comply with data protection laws including GDPR. This says that the personal information we hold about you must be:
- Used lawfully, fairly, and in a transparent way.
- Accurate and kept up to date.
- Kept only if necessary for the purposes we have told you about.
- Kept securely.
Data protection laws state that we are only able to process personal data if we have valid reasons to do so. The reasons we process your personal data include, but are not limited to, your consent, performance of a service, billing and to contact you.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
How do we collect personal data from you?
We receive information about you from you when you use our website, complete forms on our website if you contact us by phone, email, or otherwise in respect of any of our services or during the purchasing of any such service. Additionally, we also collect information from you when you sign up, enter a competition, promotion, or survey or when you inform us of any other matter. If you provide us with personal data about a third party, you warrant that you have obtained express consent from the third party for the disclosure and use of their personal data.
What type of data do we collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection.
We collect, store, and use the following categories of personal information about our clients.
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
We may collect, store, and use the following categories of personal information about clients following some coaching interventions.
- Marital status and dependants.
- Location of employment or workplace.
- Next of kin details.
These may sometimes be used:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Trade union membership.
- Information about your health, medical conditions, or disabilities.
We may also collect, store and use the following “special categories” of more sensitive personal information in respect of client information arising from some coaching interventions.
- Business address and company registration number(s).
- A management contract for the business we are engaged with.
How do we use your data?
We use information about you in the following ways:
- On many occasions, the data is used directly in the coaching process for the benefit of the client in achieving their objectives.
- To provide customer care, including responding to your requests if you contact us with a query;
- To provide you with information about events or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
- To enable us to review, develop and improve the website and services;
- To administer accounts, process payments, and keep track of billing and payments;
- To notify you about changes to our website and services; and
- To inform you of service and price changes.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest (or for official purposes).
Why do we hold information about you?
It is necessary for us to retain data on you for us to fulfill our contractual obligations and hold data for legitimate business needs.
We will only retain data for a period that is reasonably necessary.
We will not disclose your data to third parties unless you have consented for us to do so or we are otherwise required to do either contractually or under another law or enactment.
How long do we keep your data?
We retain your data only for as long as necessary in accordance with applicable laws.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may make your data anonymous so that it can no longer be associated with you, in which case we may use such information without further notice to you.
In respect of client data, please expect us to hold data relating to your instructions for a period of seven years after the completion of the last coaching interaction. The seven-year period will start from the last contact we had with the client, third party, or supplier.
Should you not contact us for seven years, we will confidentially destroy all data held about you.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered with you or be prevented from complying with our legal obligations.
How do we protect your data?
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed.
We have put in place procedures to deal with any suspected data security breach, such as but not limited to, having a proper communications plan and fixing vulnerabilities related to the breach, and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
The transmission of information via the internet is not completely secure. We cannot guarantee the security of your data transmitted online and transmission is made at your own risk. If you communicate with us by email, then you assume the risks of such communications being intercepted, not received or delivered, or received by individuals other than the intended recipient.
Who has access to your personal data?
We process your data for administration, support and the provision of services. For the avoidance of doubt, we do not and never shall sell your personal data to third parties for marketing or advertising purposes. We may pass your personal data to third parties for the provision of services on our behalf (for example processing your payment). However, we will only ever share information about you that is necessary to provide the service and we have specific agreements in place, which ensure your personal data is secure and will not be used for any marketing purposes. We may share your personal data if we are under a duty to disclose data in order to comply with any legal obligation or to protect the rights, property, or safety of Dare Coaching, our customers, or others.
What are your rights?
By law, you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object when we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
- Request to withdraw consent of the data we process. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us. You have the right to object to our use of your personal data, or ask us to delete, remove or stop using it if there is no need for us to keep it. This is known as your right to be forgotten.
Please note that we reserve the right to refuse your request where we have a legal obligation, contractual or other legitimate business interest. If we refuse your request, we will notify you of this refusal and you will have the right to appeal.
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Links to other sites
Dare Coaching may provide links to third-party sites. Since we do not control those websites, we encourage you to review the privacy policies of these third-party sites. Any information that is supplied on these sites will not be within our control and we cannot be responsible for the privacy policies and practices of these.
Where we store your personal data?
Handwritten notes taken during coaching sessions are stored in a locked cabinet.
We agree to take reasonable measures to protect your data in accordance with applicable laws.
In the event of a data breach, we shall ensure that our obligations under applicable data protection laws have been complied with where necessary.
We reserve the right to update this privacy notice at any time, and we will provide a new privacy notice when we make any substantial updates. We may also notify you in other
ways from time to time about the processing of your personal information.
You Have the Right to Complain
For more information about your rights, visit the Information Commissioners Office’s (ICO) website https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights
You have the right to make a complaint about how we process your personal data to the Information Commissioner: https://ico.org.uk/concerns
Information Commissioner’s Office
Tel: 0303 123 1113