Where we rely on legitimate interests, we have considered whether those interests are overridden by your rights and concluded that they are not. You can object at any time - see section 8.
4. Coaching conversations
Coaching is confidential, and the terms of that confidentiality are set out in your coaching agreement.
Coaching conversations sometimes touch on health, wellbeing or other sensitive matters. We do not ask for information of that kind, and you decide what to share. Where our notes record it, we rely on your explicit consent to hold it, and you can withdraw that consent at any time by contacting us.
Coaching is not therapy or medical treatment, and we do not keep clinical records.
Where an employer or other organisation is funding your coaching, we confirm attendance only. We do not tell them what was discussed unless you agree in writing.
5. Who we share it withWe do not sell your information. We share it with:
- Service providers who help us run the business - our website host, our email and office software, our email marketing platform, our scheduling tool, our video conferencing provider, our payment provider and our accountant. They act on our instructions and may only use the information to provide their service to us.
- Associates and contractors who work with us on client engagements, under written agreements that require confidentiality and appropriate data protection terms.
- Anyone we are required to share information with by law, or where there is a clear and imminent risk of serious harm to you or someone else.
A current list of the providers we use is available on request.
6. Where your information is heldOur systems are hosted in the United Kingdom, the European Economic Area and the United States. Some of the people we work with are based outside the UK, including in the European Economic Area and in India.
Where information is transferred outside the UK, we rely on the UK’s adequacy regulations where they apply, and otherwise put in place the International Data Transfer Agreement, or the UK Addendum to the European Commission’s standard contractual clauses, together with an assessment of the risks involved.
7. How long we keep it
Enquiries that do not lead to work: two years from our last contact with you.
Client and engagement records, including contracts and correspondence: seven years from the end of the engagement, to meet our accounting, tax, insurance and professional obligations.
Coaching notes: five years from the end of the coaching relationship, after which they are deleted or destroyed.
Newsletter subscribers: until you unsubscribe, and for a short period afterwards so that we can honour your request.
Accounting records: six full financial years plus the current year, as the law requires.
8. Your rightsUnder UK data protection law you have the right to ask for a copy of the information we hold about you, to ask us to correct it if it is wrong, to ask us to delete it, to ask us to restrict how we use it, to object to our using it where we rely on legitimate interests, to ask us to transfer it to another provider where it is held by consent or under a contract and handled automatically, and to withdraw your consent at any time where our use of the information depends on it.
To exercise any of these rights, email
[email protected]. We will respond within one month. There is no charge unless a request is clearly unfounded or excessive.
You can unsubscribe from our emails at any time using the link at the bottom of every email.
If you are unhappy with how we have handled your information, you can complain to the Information Commissioner’s Office at ico.org.uk, by calling 0303 123 1113, or by writing to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. We would appreciate the chance to put things right first.
9. CookiesCookies are small files placed on your device when you visit a website. They let a site remember what you have done, and let us understand how the site is being used.
The cookies we use
- Strictly necessary cookies keep the website working - remembering your cookie choices, keeping a form secure, and similar. These are set automatically and do not need your consent.
- Analytics cookies tell us how many people visit, which pages they read and how they found us. We only set these if you accept them.
- Marketing cookies allow us to measure whether an advertisement or social media post led someone to the site. We only set these if you accept them.
Your choices
When you first visit the site you can accept or reject non-essential cookies. Nothing other than strictly necessary cookies is set unless you accept. You can change your mind at any time by HOW TO REOPEN THE COOKIE SETTINGS.
You can also block or delete cookies through your browser settings. If you do, parts of the site may stop working properly.
10. Changes to this noticeWe may update this notice from time to time. The version in force is the one published on our website, and the date at the top tells you when it last changed.