Your Privacy

Privacy Notice – Waymarker Coaching

Definitions

• Personal data – this is any information about yourself as a client of Waymarker Coaching that identifies you, e.g., a name, email address, telephone number. Identification can be by such information alone or in conjunction with any other information, e.g. coaching notes.

• Data Controller – this is Waymarker Coaching and we decide, for our purposes, the way in which your personal data is processed. This is done in accordance with good practice and guidelines as offered by the General Data Protection Regulation (2018). See below.

• Data Processor – this is anyone within Waymarker Coaching who will process your personal date for the purposes identified by the Data Controller. A description of what data is processed and for what purpose is set out below.

The legal basis for processing your personal data

• The processing of personal data is governed by the Data Protection Act 1998 (DPA) and the General Data Protection Regulation 2018 (GDPR).

Data Protection Principles

The data protection principles set out under the GDPR state that personal data shall be:

• Processed lawfully, fairly and in a transparent manner in relation to individuals.
• Collected for specified, explicit and legitimate purposes only and not further processed in a manner that is incompatible with those purposes.
• Accurate and where necessary, kept up to date.
• Kept in a form which permits identification of individuals for no longer than is necessary for the purpose for which the personal data is processed.
• Processed in a manner that ensures appropriate security of the personal data.

Waymarker Coaching is responsible for demonstrating compliance with these principles.

What information do we process?

Waymarker Coaching processes the following personal data belonging to clients:

• Names and titles
• Contact details such email addresses, telephone numbers.
• Copies of invoices recording fees charged/paid.
• Information gathered as part of the enquiry and coaching process e.g., why you are wanting coaching; whether you have had coaching before.

How do we process your personal data?

Waymarker Coaching will comply with its legal obligations to keep your personal data up to date: to store and destroy it securely; to not collect or retain excessive amounts of data; to protect it from loss, misuse, unauthorised access, and disclosure; and to ensure that appropriate measures are in place to protect it.

We will use your personal data for some or all of the following purposes:

• To meet our business objectives, i.e., to maintain administrative, financial and record keeping systems appropriate to providing a professional coaching service.
• To notify you of appointment times, cancellations, and any policy/procedural changes that will affect you as a client of Waymarker Coaching.
• To seek your views and comments on our services or website.
• Where necessary to carry out comprehensive safeguarding procedures in accordance with best safeguarding practice.

Sharing your personal data

Your personal data will be treated as strictly confidential. It will only be shared with third parties where:

• You give specific permission for your coach to do so, to an identified person or professional.
• In exceptional circumstances when your coach believes that there is a risk to your well-being, health or safety, or that of others. E.g., where there is a potential safeguarding concern.
• When required to do so by law.

How long will we keep your personal data?

We will keep your personal data for six years from the date of your last coaching session. Name and minimal details will be kept for as long a necessary to satisfy ICF audit requirements for proof of coaching experience for coaching accreditation purposes. This will be explained in your first coaching session. Some information will be kept in paper format only, while other information will be kept electronically on a secure electronic drive – See Appendix A: Client Data Retention Schedule.

Your rights and your personal data

You have the following rights with respect to your personal data:

• The right to be informed – You have the right to ask Waymarker Coaching for information about what personal data (about themselves) is being processed and the rationale for such processing.
• The right of access – You have the right to access the personal data about yourself being processed by Waymarker Coaching.
• The right to rectification (correction) – You have the right to ask for corrections to your personal data where you believe that your personal data is either not up to date, incomplete or is inaccurate.
• The right to erasure (deletion) – You can ask us to delete or remover your personal data in some circumstances, such as where it is no longer need it or if you withdraw your consent (if we rely on your consent or explicit consent as our legal basis for processing your personal data).  This will generally apply to situations where coaching has ended. It is important to note that this is not an absolute right, e.g., some financial records may need to be kept by law to satisfy financial accounting/HMRC requirements.
• The right to restrict processing – You can ask us to restrict the process of your personal data in certain circumstances, such as where you contest the accuracy of your personal data. If you ask us, we will tell you where it is possible and lawful for us to do so.
• The right to object – you have the right to object to the processing of your data.
• The right to object to automated processing for decision-making – Automated processing for decision-making is not used at Waymarker Coaching.

When exercising any of these rights and to process your request, we may need to verify your identity for your security. In such cases you will need to respond with proof of your identify before you can exercise these rights.

Transfer of data abroad

No personal data held electronically will be transferred abroad.

Changes to this notice

We keep this coaching privacy notice under regular review.

Newsletters, messages and mailings. If you have subscribed to a newsletter or received information from Waymarker Coaching via email or postal mail and would like to modify or cancel these mailings, please send an email to ros@waymarkercoaching.co.uk or use the ‘Contact Us’ form on the website. For best results, forward the copy of the mailing you received from Waymarker Coaching. In such cases, we will retain minimum data to note that you opted out to avoid contacting you again.

Cookies

If you want to remove existing cookies from your device, you can implement these steps by using your browser options. If you want to block future cookies being placed on your device, you can change your browser settings to do this. When you review your browser settings you can identify the Waymarker Coaching cookies in the name. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our site. Please bear in mind that deleting and blocking cookies will have an impact on your user experience as parts of the Site may no longer work.

For more information on managing cookies, www.allaboutcookies.org/manage-cookies

Data Subject Access Requests.

You may exercise your rights to access, rectification, and deletion rights by emailing: -

ros@waymarkercoaching.co.uk

Coaching Privacy Notice

Waymarker Coaching

August 2023