Privacy Policy

As a professional coach our client and coaching relationship will always be built on transparency, trust and confidence in each other.  Confidentiality will always be paramount.  I am detailing below my privacy statement that provides you with the further confidence that I am following personal data protection laws.

I have written this statement to inform you that I am committed to protecting the privacy and security of your personal information.

This privacy notice describes how I collect and use personal information about you during and after your relationship with me, in accordance with the General Data Protection Regulation (GDPR).

Any reference to 'I' 'me' or 'my' shall mean me Tonia Andersen as a sole proprietor.

Any reference to ‘you’ or ‘Data Subject’ shall mean any individual receiving this notice for whom I hold personal data.

This Privacy Statement does not include information relating to the retention of data on limited companies as such data is not incorporated within the provisions of GDPR.

I am required under data protection legislation to notify you about the holding of information in this privacy notice.

DATA PROTECTION PRINCIPLES

I will comply with data protection laws including GDPR. This says that the personal information I hold about you must be:

  1. Used lawfully, fairly and in a transparent way.

  2. Collected only for valid purposes that I have clearly explained to you and not used in any way that is incompatible with those purposes.

  3. Relevant to the purposes I have told you about and limited only to those purposes.

  4. Accurate and kept up to date.

  5. Kept only if necessary for the purposes I have told you about.

  6. Kept securely.

 THE KIND OF INFORMATION I HOLD ABOUT CLIENTS

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection.

I will collect, store, and use the following categories of personal information about my clients.

  • Personal contact details such as name, title, telephone numbers, and personal email addresses.

  • Gender.

I may collect, store, and use the following categories of personal information about clients.

  • Marital status and dependants.

  • Location of employment or workplace.

  • Next of kin details.

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinion.

  • Information about your health, medical conditions, or disabilities.


WHY I HOLD INFORMATION ON CLIENTS

It is necessary for me to retain data on clients in order for me to fulfill my contractual obligations to the client and hold data for legitimate business needs.

I will only retain data which I reasonably require and for a period which is reasonably necessary.

I will not disclose your data to third parties unless you have consented for me to do so or I am otherwise required to do either contractually or under another law or enactment.


HOW I COLLECT PERSONAL INFORMATION

I collect personal information about clients directly from themselves when they contact me via telephone, email, social media or my through my website.

Client and business data is stored within a GDPR compliant Gmail cloud account with a mirrored copy of the data saved on a standalone server located in my office that is password encrypted.  Data on current clients that I am actively working with is also stored in my mobile telephone that is also password encrypted. 

I reserve the right to change the systems in which data is stored without notification to another equivalent system but at all times I will ensure the appropriate security of your data and GDPR compliance.

HOW I WILL USE YOUR INFORMATION.

I will only use your personal information when the law allows me to. Most commonly, I will use your personal information in the following circumstances:

  1. Where I need to perform the contract I have entered into with you.

  2. Where I need to comply with a legal obligation.

The situations in which I will process your personal information are listed below.

  • Administering the contract I have entered into with you.

  • To market other products or services which I offer which may be of interest to you.

  • To inform you about updates about my services.

  • To administer my business which may include disclosure of client data to my accountant.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

In certain circumstances listed above, I hold your data to market other services to you, or send you information that I think may interest you. I have a legitimate business interest in retaining your data for this purpose, but you may ‘opt out’ of receiving these types of communication from me.


 THE KIND OF INFORMATION I HOLD ABOUT INDIVIDUALS OTHER THAN CLIENTS AND HOW THIS DATA IS USED

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

During my day to day business I acquire information regarding individuals other than my clients and I will retain this data where I have a legitimate business reason to do so.

Typically, I acquire personal data on individuals, third parties and suppliers other than my clients in the following circumstances:

  1. Where I have met individuals, third parties and suppliers at networking or other marketing events;

  2. Where individuals, third parties or suppliers have made enquiries with me regarding possible services but have not subsequently become clients of my business;

  3. Where I have dealt with individuals, third parties or suppliers in the capacity as suppliers of goods or services to me;

  4. Where I have regular business-related dealings with you.

I have a legitimate business interest in retaining this data to send event details or other updates relating to my services or something that I believe relates to your interests. You have the right to ask me to erase or rectify your data and you have the right to opt out of receiving marketing, networking information or information I think might be of interest to you.


Why might I share your personal information with third parties?

I will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where I have another legitimate interest in doing so.


DATA SECURITY

I have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. 

The transmission of information via the internet is not completely secure. I cannot guarantee the security of your data transmitted online and transmission is made at your own risk. If you communicate with me by email then you assume the risks of such communications being intercepted, not received or delivered, or received by individuals other than the intended recipient.


DATA RETENTION

How long will I use your information for?

I will only retain your personal information for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances I may anonymize your personal information so that it can no longer be associated with you, in which case I may use such information without further notice to you.

In respect of client data, you can expect me to hold data relating to your instructions for a period of seven years after completion of the last coaching interaction. The reason for this is that the Limitation Act 1980 typically provides that legal proceedings for breach of contract or negligence can be brought up to six years after the events. I therefore have a legitimate business interest in retaining the data should any subsequent legal proceedings ensue.

The seven-year period referred to above will start from the last contact I had with the client, third party or supplier, to ensure I am able to assist as and when I need to. Should you not contact me for seven years, I will confidentially destroy all data held for you.


RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform me of changes

It is important that the personal information I hold about you is accurate and current. Please keep me informed if your personal information changes during your working relationship with me.


Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information I hold about you and to check that I am lawfully processing it.

  • Request correction of the personal information that I hold about you. This enables you to have any incomplete or inaccurate information I hold about you corrected.

  • Request erasure of your personal information. This enables you to ask me to delete or remove personal information where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal information where you have exercised your right to object to processing (see below).

  • Object to processing of your personal information where I am relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where I am processing your personal information for direct marketing purposes.

  • Request the restriction of processing of your personal information. This enables you to ask me to suspend the processing of personal information about you, for example if you want me to establish its accuracy or the reason for processing it.

  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that I transfer a copy of your personal information to another party, please contact Tonia Andersen at shadowhealing@toniaandersen.com.

Please note that where you ask me to erase, correct, object to process or seek to restrict my processing of data I may refuse your request where I have a legal obligation, contractual or other legitimate business interest to refuse your request. If I refuse your request then I will notify you of this refusal and you will have the right to appeal.


No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, I may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, I may refuse to comply with the request in such circumstances.


What we may need from you:

I may need to request specific information from you to help confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.


RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact shadowhealing@toniaandersen.com.  Once I have received notification that you have withdrawn your consent, I will no longer process your information for the purpose or purposes you originally agreed to, unless I have another legitimate basis for doing so in law.


DATA PRIVACY MANAGER

I have appointed myself as a Data Privacy Manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how I handle your personal information, please contact me at helen@helenfostercoaching.co.uk.  You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.


Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF


COOKIES POLICY

 My website does not uses cookies as part of the user website experience. [Cookies are small files saved to the user’s computer’s hard drive that track, save and store information about the user’s interactions and usage of the website].  http://helenfostercoaching.co.uk is transparent and free of any data tracking including Google Analytics.  Unfortunately, I cannot guarantee that your user experience will be totally free from Cookies, data tracking or data analytics if you found the website via a third-party website or search engine.

Other cookies may be stored to your computer’s hard drive by external vendors if the website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.


 CHANGES TO THIS PRIVACY NOTICE

I reserve the right to update this privacy notice at any time, and I will provide a new privacy notice when I make any substantial updates. I may also notify you in other ways from time to time about the processing of your personal information.


CONTACT AND FURTHER INFORMATION

If you have any questions about this privacy notice or wish to submit a complaint, then please email Helen@helenfostercoaching.co.uk.

You have the right to make a complaint to the Information Commissioners Office or such other regulatory body or supervisory authority as may be appointed from time to time.

If you make a complaint then I will respond to let you know how your complaint will be handled.