DATA PRIVACY NOTICE (GDPR)
In order for us to fulfil our responsibilities for coaching, supervision and other services we will need to gather, record and use personal information (data) about you. The General Data Protection Regulation (2018) requires us to be clear about what happens to this information, how it is kept, including where it is filed, how long we keep it and what your rights are.
Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. This will include information such as your name and contact information (including email address and phone number) when you agree to receive information from The Scultura Clinic, as well as any other relevant personal information that will help us signpost you to the appropriate service. This will include information that you give us over the phone, face to face, by letter or by email.
How do we process your personal data?
We comply with our obligations by keeping your personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We use personal data for the following purposes, not all of which will be relevant to yourself, and on the following legal grounds:
HOW WE USE YOUR PERSONAL DATA
- To administer and maintain our records and accounts
- Necessary for clear communication of our services and/or legal obligations with you
- To direct you to the appropriate part of our services
- Necessary for clear communication of our services
- To inform you of marketing and fundraising opportunities
- Necessary for clear communication of our services
Sharing your personal data
We will treat your personal data as confidential. Any sharing of such information will only be carried out anonymously e.g. collation of outcomes from a programme which is presented as numbers and percentages.
In exceptional circumstances we may have an ethical or legal basis for providing information to a relevant authority. An example is where we have concerns about your own or someone else’s safety from serious harm, or if we are made aware of serious illegal activity, or if there is any disclosure of any recent or current acts of abuse upon a child or a vulnerable adult. In any of these examples, we may be under an obligation to inform the relevant authorities
We will discuss any proposed disclosure with you unless we believe that to do so could increase the level of risk to you or someone else.
Any such disclosure would be restricted to relevant information, disclosed to appropriate people or organisations, and for appropriate reasons likely to alleviate the exceptional circumstances.
We will not otherwise disclose your personal data to anyone without telling you, for example, by updating this Privacy Notice.
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for the services requested, currently that will be 7 years from the date of your last coaching session for those in receipt of coaching. In the case of training and development any personal data will be held for 6 years beyond the delivery of a course. It is then disposed of securely. You may request that your personal data is removed from our website or click on ‘unsubscribe’ at the bottom of any email sent to you.
Your rights and your personal data
Unless subject to an exemption under the law, you have the following rights with respect to your personal data: –
- The right to request a copy of your personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary for me to retain such data;
- Where we have relied on your consent for the processing of your data, you have the right to withdraw your consent to the processing at any time;
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data (in relation to marketing);
- The right to lodge a complaint with the Information Commissioner’s Office. You can contact the Information Commissioner’s Office on 0303 123 1113 or via email (see the “Contact Us” page on their website: ico.com or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
- Transfer of data abroad
We do not transfer data outside the UK.
If we wish to use your personal data for a new purpose not covered by this Privacy Notice, then we will provide you with a new Privacy Notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
How we will communicate with you?
To provide coaching or training to you or your organisation (covered by a separate Privacy Notice), we will need to contact you either by telephone and/or by post or email. Such communication methods will only be used to arrange, change or confirm appointments and to send information to you. In the case of coaching our services will be delivered ‘face to face’, or exceptionally by telephone and contained within agreed times. Training or professional development services will be delivered within agreed times and be ‘face to face’. The only exception to this will be in specific or unusual situations where an alternative arrangement has been explicitly agreed and made between us.
To exercise all relevant rights, ask any questions, or send us a complaint please in the first instance contact us at the address provided above.
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