Privacy Policy

 

Last reviewed: April 2023

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GDPR: DATA PRIVACY NOTICE

Alice Penn MD Ltd("We") is registered in England - Company number 14764889. The registered address is 138 Gloucester Terrance W2 6HR.  

We are governed by the law of England & Wales and are subject to the exclusive jurisdiction of the Courts of England & Wales.

We are committed to protecting and respecting your privacy and we take the protection of your personal data very seriously.

We do not sell personal data about anyone for any purpose.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us when you use our website and contract for our services such as Coaching, Facilitation and Leadership & Personal Development Training.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

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Definitions

Data controller - A controller determines the purposes and means of processing personal data.

Data processor - A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Categories of data: Personal data and special categories of personal data

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Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

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Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

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Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

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Who are we?

Alice Penn MD Ltd is the ‘Data controller’. This means we decide how your personal data is processed and for what purposes.

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The purpose(s) of processing your personal data

We use your personal data for the following purposes:

To support you through a series of coaching sessions for you or your team
To support you through Leadership and Personal Development training interventions.

Our website maintains an access log containing the IP addresses of those who have visited the site. We do not use this information in any routine processes. It might be used in diagnostic work for instance to investigate a breach of security.

We may request feedback from you such as through surveys. We may also send you further information for maximising the benefit of Coaching and Training.

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The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

Personal data –cv, contact details
Personal data –COACHEE: cv, contact details, pre diagnostic form, MBTI and/or other diagnostic tools or psychometric profiles

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What is our legal basis for processing your personal data?

a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data is: LEGITIMATE INTEREST
b) Special categories of personal data (article 9 of GDPR)
Our lawful basis for processing your special categories of data is: Processing necessary for carrying out obligations under employment law.

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Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared only with my administration team and coaches that are involved in the delivery of sessions.

My Accountant will see your name on invoices but has no access to any other information. I may share contextual information with my Coaching team but not specific identifiable data.

With my permission my IT Consultant XXXX has full access to my IT systems with explicit and implied confidentiality.

We may pass your information to our third party service providers for the purposes of completing tasks and providing services to you on our behalf e.g. psychometric survey providers. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service. They will be GDPR compliant and will have equal obligation to keep your data secure and are not permitted to use it for their own direct marketing purposes.

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How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes and use the following criteria to determine how long to retain your personal data.

Coaching: Notes are retained for 2 years after the last coaching session or last meaningful contact as many coaching contracts and relationships are continued after periods of pausing.

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MBTI or other psychometric or diagnostic Profiles : These are retained for 2 years after the last coaching or training session or last meaningful contact as many coaching and development contracts and relationships are continued after periods of pausing. Your Personal profile will not be shared with any other person unless you give explicit permission. If the profiling has been contracted in relation to teambuilding or training then an Employer may request team data. We will share this but not your full and personal profile. You alone choose who and when to share this.

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Invoicing: Financial data has to be retained legally for 6 years.

Email and mobile numbers: will be retained for 6 years after last point of contact for ‘keeping in touch’ purposes. This information is never sold or passed on to any third parties unless through your express consent.

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Deletion of Personal Data

With the exception of any legal requirement all or some of your personal data can be deleted at any time at your request. Deleted means deleted digitally and paper copies destroyed by shredding or burning. To make such a request please contact the Data Controller.

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Providing us with your personal data

You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so means that we are unable to support you meaningfully through a Coaching or Leadership & Personal development Training relationship.

Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

• The right to request a copy of the 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 to retain such data;

• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);

• 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, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

 

Transfer of Data Abroad

We use Google’s GSuite for email and contact management services. Google has servers worldwide, and your data in the form of emails and contact details may be transferred out of the EEA on Google servers. Google is compliant under GDPR and is subject to the EU-US and Swiss-US Privacy Shield Frameworks.

We use DropBox for file storage and sharing. DropBox complies with the EU-US and Swiss–US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use and retention of personal data transferred from the European Union, the European Economic Area, the United Kingdom and Switzerland to the United States.

Financial information, such as invoices, are stored in Xero. Xero uses a data hosting provider whose servers are located in the United States. Xero confirms in it’s Privacy Policy that data is only transferred to countries that have been identified as providing adequate protection for EEA data or to a third party where Xero have approved the transfer mechanisms in place to protect personal data.

We will never sell your personal information to anyone for any purposes and we will not use your personal profile or personal details for marketing purposes.

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Automated Decision Making

We do not use any form of automated decision making in our business.

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Where your Data is stored and how we keep it secure

We place great importance on the security of personally identifiable data and take all reasonable precautions in relation to the security of your personal data so as to prevent unauthorised access to it from within and outside the organisation. Non-sensitive details, for example, your email address etc are transmitted normally over the internet and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

Your data is stored on the Wix service. All data on Wix is subject to zero-knowledge encryption. This means that data is automatically encrypted by us with a private key known only to us before transmission to Wix over an encrypted connection. In the unlikely event of a security breach at Wix or Microsoft Azure, your data is unreadable and therefore secure and confidential.

Your contact details and email correspondence with us is stored on Google’s GSuite servers, located within and without the EEA. Google is subject to EU-US Privacy Shield agreement and is GDPR Compliant. Your data is held securely at Google but it is not subject to zero-knowledge encryption. This means that in the unlikely event of a security breach at Google, your email correspondence with us and your contact details might be read by a third party.

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Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

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Changes to our privacy policy

From time to time we may changes we may make changes to our privacy policy and we will advise you accordingly via email.

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How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Officer – Dale Harrison dale@alicepennmd.com.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on +447828110040