PRIVACY NOTICE
Empowerment Coach Ltd is committed to ensuring that your privacy is protected.
This Privacy Notice sets out what personal data we collect from you and how we use it when you use the services provided by Empowerment Coach Ltd or otherwise interact with us.
Language used in this privacy notice and the definition:
You, your, data subject - Relates to you as a natural living person
We, our - Empowerment Coach Ltd & trading styles
Your representative - Someone or some people who legally acting on your behalf
Third party (ies) - Refers to external suppliers who your personal data may be shared with (E.G. Delivery companies)
Data - Any personal information we hold on you
GDPR - General Data Protection Regulation (2016)
ICO - Information Commissioner’s Office. The UK Data Protection Regulator
EEA/EU - European Economic Area/ European Union States
Legitimate Interest - ICO 3 elements:
Identify a legitimate interest;
show that the processing is necessary to achieve it; and
balance it against the individual’s interests, rights and freedoms
Scope of this Privacy Notice
This Privacy Notice covers how we handle your data from this website and within our organisation. It does not include any website you have used to access this website or any website that you access from this website.
GDPR
Under GDPR, we act as a data controller (make decisions) for your personal data that we collect.
Who collects your personal data and is responsible for its use?
Empowerment Coach Ltd. We are responsible for looking after your personal data that we collect, use and process in accordance with the UK Data Protection Act (2018).
Lawful basis for processing personal data
We will only process your personal data using the lawful definitions provided by the ICO: Consent, Contractual, Legal Obligation, Vital Interest, Public Task and Legitimate Interests
Special Category data
We will comply with section 9 of GDPR, ensuring that Special Category data is handled using both a lawful basis and that such data is processed in a more sensitive way. For example, information about an individual’s:
race
ethnic origin
politics
religion
trade union membership
genetics
biometrics (where used for ID purposes)
health
sex life; or
sexual orientation.
What personal information do we collect?
In the course of our dealings with you, we will collect information about you. We refer to that information as personal information or personal data. This information may include:
name and job title
contact information, including email address, telephone numbers and postal address
demographic information and information about your preferences and interests
information contained in your CV or profile
information contained in and records of communications between us, including recordings of telephone calls
Sometimes you may provide us with personal data about another person. If you do, you must ensure that before you provide us with their personal data, you have their agreement to do so and that they are aware of the ways in which we use personal data as set out in this Privacy Notice.
How do we use the personal information that we collect?
We will use your information in the operation of our business and, in particular, we will use your personal information to:
administer your relationship with us;
answer your questions and enquiries;
comply with our legal and regulatory duties.
In addition to the above, we may anonymise your personal information and use it in the ways described below in the section 'How do we use anonymous information?'.
How do we use anonymous information?
Anonymous information is information that does not identify you, but it may be created using personal information you have provided to us.
We may anonymise the information you provide to us and aggregate it with other anonymous user data we hold. We may use this anonymous information to better understand our users, develop and improve our services, create and publish reports, provide products and services for our clients and other third parties, and as we otherwise determine. We do not use this anonymous information in a way that you can be identified.
Who might we share your personal information with?
We may share your personal information with various third parties in connection with the purposes identified above. These third parties include the following:
Regulatory or law enforcement agencies or other third parties if we believe that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings.
Do we use organisations to process personal data on our behalf?
No.
Timescales that we keep your data for
The timescale for this will vary depending on the requirement. The criteria for this include:
The reason we are using your data. We will keep the minimum amount of data required for that reason and for the timescale that that reason requires (E.G. contractual membership periods)
Legal requirements and where a minimum timescale is set (E.G. Her Majesty's Revenue and Customs (HMRC))
We will keep your data for the term you have consented to, the contracted term between us or where there is a legitimate interest for us to remain in contact with you in case of any queries that you may have (E.G. copy of the original agreement) or for legally required reasons (E.G. HMRC), whichever is the longest period.
How do we keep your data secure?
We are committed to ensuring that your information is secure.
In order to prevent unauthorised access or disclosure, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect.
How can you get a copy of the personal information we hold about you or correct inaccurate information you think we may hold?
You may request details of the personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you, please write to:
tomswanston@mac.com
If you believe that any information we are holding on you is incorrect or incomplete, please write to us at the above email address. We will promptly correct any information found to be incorrect.
How can you exercise your other rights under data protection law?
Your Data Protection & Privacy Rights
There are various rights that you have as a UK natural living person (individual) under the GDPR. Below are the abbreviated ICO definitions and include:
The right to be informed - Individuals have the right to be informed about the collection and use of their personal data
The right of access - Individuals have the right to access their personal data and supplementary information
The right to rectification - Individuals have the right to have inaccurate personal data rectified, or completed if it is incomplete
The right to erasure - The right for individuals to have personal data erased. This is also known as ‘the right to be forgotten. Please note this right is not absolute and only applies in certain circumstances
The right to restrict processing - The right to request the restriction or suppression of their personal data. Please note this is not an absolute right and only applies in certain circumstances
The right to data portability - The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services
The right to object - Individuals have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling), direct marketing (including profiling) and processing for purposes of scientific/historical research and statistics
The full ICO rights under GDPR can be seen at the Internet link below or calling them on 0303 123 1113:
If you wish to exercise your other rights, please write to us at the below address or email us at data.controller@intouchnetworks.com:
The Data Protection Officer
In Touch Networks Ltd
3rd Floor
3 Hardman Square
Spinningfields
Manchester
M3 3EB
Do we use cookies and similar technologies on our website?
No.
Does our website contain links to other sites and who is responsible for the data collected by those sites?
No.
Children Under Thirteen
Our products and services are not intended to be used by children under 13 years old. We will never knowingly collect data from or on children below 13 years old. If you become aware of such a child (or another person) supplying data on that child to us, please contact using the details shown in the ‘Contact us’ section at the end of this Privacy Notice.
Complaints
We would always welcome the opportunity to rectify any complaints that you have about your data and privacy held with us and can be contacted as shown in the ‘How can you exercise your other rights under data protection law?’ section above. If you would like to make a complaint to the ICO, their contact details are:
By phone - 0303 123 1113
Online - https://ico.org.uk/concerns
Will this Privacy Notice change?
We may need to change this Privacy Notice from time to time to ensure that it accurately reflects the ways in which we process your personal data. Any changes will be posted on this webpage. Please check this page from time to time so that you aware of the ways in which we process your personal data.
This Privacy Notice was last updated on 1st January 2019.