Privacy Policy

My contact details 

Name:  Sally Chapman

Address: Cartref Cottage, Axminster Road, Musbury, Devon, EX13 8AZ

Phone Number: 07976 520936

E-mail: sally@shinecoaching.org.uk 

Website: https://shinecoaching.org.uk/ 

As a professional coach our client and coaching relationship will always be built on transparency, trust, and confidence in each other.  Confidentiality will always be paramount.  I am detailing below my privacy policy that provides you with the further confidence that I am following personal data protection laws.

I have written this policy to inform you that I am committed to protecting the privacy and security of your personal information.

This privacy policy describes how I collect and use personal information about you during and after your relationship with me, in accordance with the General Data Protection Regulation (GDPR).

This notice applies to:

1. All Clients
2. All Third Parties and Suppliers with whom we have dealings in the ordinary course of our      business including those individuals with whom we send marketing information.

Any reference to ‘we’, ‘us’, ‘our’, ‘the company’ shall mean me Sally Chapman as a sole trader in the name of Shine Coaching.

Any reference to ‘you’ or ‘Data Subject’ shall mean any individual receiving this notice for whom I hold personal data.

This Privacy Policy does not include information relating to the retention of data on limited companies as such data is not incorporated within the provisions of GDPR.

This Privacy Policy also applies to my website; https://shinecoaching.org.uk/

In most circumstances your data will be held by me as a “Data Controller”. This means that I am responsible for deciding how I hold and use personal information about you. I am required under data protection legislation to notify you about the holding of information in this privacy policy.

I may update this notice at any time.

It is important that you read this notice, together with any other privacy statements I may provide on specific occasions when I am collecting or processing personal information about you, so that you are aware of how and why I am using such information.

Data Protection Principles

I will comply with data protection laws including GDPR. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only if necessary for the purposes we have told you about.
6. Kept securely.

The type of information I collect and hold about clients

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.

I will collect, store, and use the following categories of personal information about my clients.

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
• Date of birth.
• Gender.

I may collect, store, and use the following categories of personal information about clients following some coaching interventions.

• Marital status and dependents.
• Location of employment or workplace.
• Next of kin details.

I may collect, store, and use the following categories of personal information about business clients.

• Information about your race or ethnicity, religious beliefs, sexual orientation and political      opinions.
• Trade union membership.
• Information about your health, medical conditions, or disabilities.

I 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 contact for the business I am engaged with

How I get the information on clients and why I hold it

I collect personal information about clients directly from themselves when they contact me via telephone, email, social media or through my website.

Client and business data is stored within a GDPR compliant OneDrive cloud account located in my office that is password encrypted.  Data on current clients that I am actively working with is also stored in my mobile telephone that is also password encrypted.  If our coaching is carried out via Zoom or a similar communication application, contact data will be stored within the application for the duration that we are actively in a coaching relationship.

I reserve the right to change the systems in which data is stored without notification to another equivalent system but at all times I will ensure the appropriate security of your data and GDPR compliance.

It is necessary for me to retain data on clients in order for me to fulfil my contractual obligations and hold data for legitimate business needs.

I will not disclose your data to the third parties unless you have consented for me to do so, or I am otherwise required to do either contractually or under another law or enactment.

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

1. Your consent. You can remove your consent at any time. You can do this by contacting me, Sally Chapman, by email at sally@shinecoaching.org.uk.

2. We have a contractual obligation which we have entered jointly.

3. Where we need to comply with a legal obligation.

4. Where we have a legitimate interest.  

We may also use your personal information in the following situations, which are likely to be rare:

5. Where I need to protect your interests (or someone else’s interests).

6. Where it is needed in the public interest (or for official purposes).

Situations in which I will use your personal information

I need all the types of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. The situations in which I will process your personal information are listed below.

• Administering the contract I have entered into with you.
• Dealing with legal disputes involving you.
• To prevent fraud.
• To market other products or services which I offer which may be of interest to you.
• To inform you about updates about my services.
• To administer my business which may include disclosure of client data to my accountant.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

In certain circumstances listed above, I hold your data to market other services to you, send you inspirational communication or resources, or send you information that I think may interest you. I have a legitimate business interest in retaining your data for this purpose, but you may ‘opt out’ of receiving these types of communication from me.

Data retention - How long will I use your information for

I will only retain your personal information for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances I may anonymise your personal information so that it can no longer be associated with you, in which case I may use such information without further notice to you.

In respect of client data, you can expect me to hold data relating to your instructions up to a maximum period of seven years after completion of the last coaching interaction. The reason for this is that the Limitation Act 1980 typically provides those legal proceedings for breach of contract or negligence can be brought up to six years after the events. I therefore have a legitimate business interest in retaining the data should any subsequent legal proceedings ensue.

Given the nature of my services clients often return to me with repeat instructions within weeks, months or years of contacting me in the first instance. The seven-year period referred to above will start from the last contact I had with the client, third party or supplier, to ensure I am able to assist as and when I need to. Should you not contact me for seven years, I will confidentially destroy all data held for you; any data from my OneDrive account will be securely deleted and any hard copies will be shredded and disposed of securely.

Your data protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information. 

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. 

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances. 

Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, I have one month to respond to you. Please contact me at sally@shinecoaching.org.uk if you wish to make a request.

How to complain

If you have any questions or concerns about this privacy policy or how I handle and use your personal information, please contact me at sally@shinecoaching.org.uk. 

You can also complain to the ICO if you are unhappy with how I have used your data.

The ICO’s address: 

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Cookies Policy

My website uses cookies as part of the user website experience. Cookies are small files saved to the user’s computer’s hard drive that track, save, and store information about the user’s interactions and usage of the website.   

Changes to this Privacy Policy

I reserve the right to update this privacy policy at any time, and I will provide a new privacy policy when I make any substantial updates. I may also notify you in other ways from time to time about the processing of your personal information.

Dated: 1 July 2021