Privacy policy

1. Introduction

As a professional coach, I take your privacy very seriously and commit to protecting your data and maintaining confidentiality unless release of information is required by law.

This privacy policy describes my privacy practices and approach regarding the collection and use of any personal data I collect from you, or that you provide to me. I may update this Policy from time to time as required. 

I (Sally May) have been working as a sole trader and now as a part of my own limited company, and as such am responsible for your data. I commit to keep, store and dispose of appropriate and accurate records of my work with clients, including electronic files and communications, in a manner that ensures confidentiality, security and privacy, and complies with UK laws regarding data protection and privacy. I follow the European Mentoring & Coaching Council’s Code of Ethics.

Any questions regarding this Policy and my privacy practices should be sent by email to sally@sallymay.co.uk.

2. The information I hold and how I use it

I collect information that you give me when you fill in a form on my website (www.sallymay.co.uk), subscribe to my services or mailing list, attend my events, participate in a survey or complete a feedback form or by corresponding with me by phone, e-mail or by giving me your business card.

If you engage me to provide coaching services, I may also, with your permission, hold notes taken during coaching sessions on paper and electronically. I review this information and use it to reflect on how to best serve you as a coach. A key role of a coach is to offer observations to help a client with their own self-awareness, and I may therefore refer to notes from earlier sessions, for example, to help you understand how much progress you have made.

As a client, your personal details may include your name, address, private and corporate e-mail address and phone number; financial information; CV/resume and photo; assessment or exercise responses; any information you choose to share with me such as personality profiles, organisational charts; email exchanges between us; and links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

This information is held and used by me for some or all of the following purposes:

  • To assist me in providing you with career and leadership coaching services;

  • To support my Continuing Professional Development : name, e-mail, address and number of coaching hours e.g. I would share this information with the International Coaching Federation (ICF) for continued professional coach accreditation;

  • To deepen my understanding, support my professional development and enable me to deliver the best possible coaching, through discussion of anonymised issues with my professional coaching supervisor;

  • To improve my customer service and make my services more valuable to you;

  • To notify you about upcoming events, news and offers when you have granted me permission to do so.

3. Where is your personal data stored?

Any handwritten notes I may take relating to client consultations are kept in a lockable cupboard. Contracts and invoices are maintained separately, also in a lockable cupboard. All the other personal data I have is stored on a password-protected computer, and emails are on my secure professional email system.

If you request assessment services, such as psychometric or self perception tools, your data may be transferred to and processed by third parties outside of the European Economic Area (”EEA”). It may also be processed by one of my suppliers. This includes web hosting services and the provision of marketing services. By submitting your personal data, you agree to this transfer, storing or processing. I take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

 

4. Disclosure of your information

I will share your information responsibly with selected third parties including:

  • Providers of assessments, psychometrics and self-perception tests that you decide you wish to take as part of a coaching or development programme;

  • International Coach Federation/European Mentoring & Coaching Council for purposes of Continuous Professional Development;

  • Colleagues with whom I co-host events to which you have consented to be invited, as we will share an account to manage logistics (e.g. Eventbrite).

  • Marketing and technology platforms and suppliers Mailchimp and SurveyMonkey (I do not currently use these platforms but reserve the right to do so in the future, and will obtain your consent to include your name on them).

These suppliers have their own privacy policies on their websites which you may check if you wish to. I do not accept any responsibility or liability for their policies whatsoever as I have no control over them.

I may disclose your personal information to third parties where I am legally required to do so (e.g. in case of illegal activities, danger to self or others).

In the event that I am hired by a sponsor (e.g. HR), I will, as usual, respect client confidentiality and ensure that the contract clearly states that the coaching client’s consent is required for any personal data to be shared.

5. Retention of your data

I understand my legal duty to retain accurate data and only retain personal data for as long as I need it for my legitimate business interests and that you are happy for me to do so. I segregate the  data I hold so that I keep different types of data for different time periods. The criteria I use to determine whether I should retain your personal data includes:

  • The nature of the personal data;

  • Its perceived accuracy;

  • My legal obligations;

  • Data required for purposes of Continuing Professional Development

Depending upon the criteria used as to whether I should retain your information, I may:-

  • Retain your personal data (first name, last name, email address, start and end date of the coaching programme, number of coaching hours received) on a coaching log

  • Retain your personal data (name and address) on copies of the invoices I have sent to you for as long as required by HMRC (UK tax authorities) (5 years)

  • Retain a copy of the contract(s) signed for our work together for 7 years

  • Retain anonymised handwritten notes relating to our consultations, so that we can refer to them should you wish to have additional coaching, and in the unlikely event that we are legally required to produce records of our discussions (7 years). I may also need these notes to support my ongoing accreditation

  • Retain your personal data (first name, last name, email address) on a mailing list (e.g. Mailchimp) if you have opted in to receiving marketing information from me.

All other client information and data collected during the course of your coaching programme, whether held on paper or electronically, will be destroyed on completion of your coaching programme.

6. What are your rights?

You have the right to ask me not to process your personal data for marketing purposes. You can exercise your right to accept or prevent such processing by checking certain boxes on the forms I use to collect your data/responding to emails with “unsubscribe”.

You have the right to request information about the personal data I hold on you at any time. If you would like to make a request for information please email sally@sallymay.co.uk. 

You have the right to request modifications, updates or removal of your data. I may ask you to verify your identify and for more information about your request.

You have the right to decline any requests from me to process your data in any way (for example as part of a research project), and to restrict the amount of processing I may carry out.

7. How do I protect your personal data?

I endeavour to take all reasonable steps to protect your personal data but cannot guarantee the security of any data you disclose online. You accept the inherent security implications of sending information over the Internet and will not hold me responsible for any breach of security unless I have been negligent.

All information you provide to me is stored on secure password protected systems. I take all reasonable care to avoid clicking on potentially malicious links or attachments to ensure risk from phishing and other malware is minimal.

Any handwritten notes are anonymised and maintained separately to documents which have your name on them, and are in a lockable cupboard. 

8. Use of cookies

On occasion, I may gather information about your computer to provide statistical information regarding the use of my website to help improve my services.

Such information will not identify you personally. It is statistical data about visitors and their use of my website. This statistical data does not identify any personal details whatsoever. It is used by me to analyse how visitors interact with the website so that I can continue to develop and improve it. All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies.

 

 Updated on 30th November 2022