Under the General Data Protection Regulation (GDPR) which comes into force on 25 May 2018, I have a legal duty to protect the personal data I collect from you. Personal data means any information capable of identifying an individual.
I am committed to ensuring that your privacy is protected at all times, not only because it's a legal requirement but because it builds trust and enhances our professional relationship.
Any information you provide is only used in accordance with this policy.
This website is not intended for children under 13 years of age. If you are under 13 please do not use this website and do not provide any personal information.
For the purposes of this policy, Minara Coaching Ltd is the data controller and processor and may be referred to in this document as 'I', 'we', 'me' or 'us.
Full Name: Minara Coaching Ltd
Registered Address: Woodberry House 2 Woodberry Grove London N12 0DR
WHAT INFORMATION WILL I COLLECT FROM YOU AND WHEN?
1 - Please be assured that I will only collect data from you that is necessary and relevant.
2 - You won't be asked to provide any personal information if you simply want to browse the content on this website.
3 - However, if you complete the Acuity Scheduling Form because you want to book a free consultation with me, then you will have to provide your full name, e mail address and telephone number. This is necessary for us to start communicating with one another.
The GDPR identifies a number of lawful grounds for the processing of data. Our lawful ground for collecting/processing this data is Legitimate Interests. In this case, legitimate interests include: establishing communication and keeping records.
4 - Similarly, if you sign up for one of my workshops through Eventbrite, you will be providing your full name, e mail address and telephone number - without providing this information, you will not be able to book a ticket for the workshop. The lawful ground again is Legitimate Interests - establishing communication and keeping records.
5 - If we then enter into a one to one coaching relationship or if you attend an event or workshop organised by Minara Coaching, you will be sharing other information with me . This may include personal information about yourself, as well as 'sensitive' data'. Sensitive data refers to data that includes details of your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions and trade union membership, as well as information about your health and genetic and biomedical data. Although I won't specifically ask for these details, you might provide this information during face to face contact with me or during telephone conversations or by email or letter or during online communications. You may share this information with me because you deem it necessary for our on-going coaching relationship so that I can provide the service you require. My lawful ground for processing personal and sensitive data is to fulfil my contractual obligation to you as a client who has requested my services.
6 - When you purchase a service from Minara Coaching, we will collect payment via Stripe and will collect data relating to your name, billing address, telephone number, e mail address (for receipts), purchase details and card details. Our lawful grounds for processing this data is contractual - so we may collect payment, provide the service you have paid for and keep a record of the transaction.
7 - Some data (eg - your IP address) is collected automatically when you visit this website, through cookies and server log files. (Please read the Cookies Policy for more information about this). Our analytics tracking system will also collect other technical data including details of your browser, page views, navigation paths, number of times you visit this website, length of time on each page and so on. Our lawful grounds for processing this data are legitimate interest - to enable us to properly administer our website and to monitor and develop our marketing strategy in order to develop the business.
8 - I may occasionally ask you for testimonials and evaluations of the services I have provided. Your feedback is important because it tells me what I am doing well and what I need to get better at. It also helps with marketing. You may provide the feedback by letter or e mail or on my Facebook page, either as a post or as a video testimonial. The lawful grounds for seeking this information is legitimate interest - developing and growing my business and promoting my services.
HOW DO I USE YOUR INFORMATION?
Just to summarise what I said in the previous section, I will use the information I collect from you in the following ways:
- To establish and maintain contact with you
- To provide a range of relevant coaching services to you
- To tailor my coaching services to your specific needs so I can deliver a service that best suits you
- To keep a record of our contractual relationship for administrative, insurance and legal purposes
- To share information with you about my existing and new services
- To ask for testimonials, evaluations and reviews of my services so I can identify what I am doing well and what I need to do better and to promote my business.
HOW DO I STORE AND SECURE YOUR INFORMATION?
1 - If you attend a workshop or coaching course I deliver, I will have your name, telephone number and e mail address on my laptop. And I will have your hand-written feedback and testimonial which you will provide at the end of the session, which will be kept in my Testimonials folder in my office.
2 - If you participate in the Free Consultation, I will have your name, telephone number and e mail address as well as hand-written notes of the call, which I make on the Minara Consultation template. If you then sign up for a coaching programme, this template will form part of the Client Records folder. If you don't sign up for a coaching programme, I will keep the notes in a Pending File for 3 months and then shred them. At that point, I will also delete the electronic data I have.
3 - If you engage in a coaching programme, I will create a Client Records folder which will contain, as well as the above, a copy of your Coaching Agreement, hand-written notes from our sessions, session plans and reflections. For legal and insurance purposes, I have to store this data for 5 years after our coaching contract ends.
4 - All paper files are stored in a locked cabinet in my work-space.
5 - With regards to online information, I implement a variety of security measures to ensure your information is stored safely and to guard against unauthorised access:
- My website uses SSL(Secured Sockets Layer) encryption to protect all network traffic between us. This means that all information travelling to and from my website is safe against interception by third parties who might otherwise use that information without your consent.
- My laptop, telephone and wifi router are password protected.
- My laptop has anti-virus and internet security software which protects it from malware as well as phishing and hacking attempts.
- I also have a feature on my laptop and telephone which enables me to wipe out all information in the event that either of these devices is lost or stolen.
6 - The security measures in place ensure that your data cannot be accessed by anyone other than me and any employee or partner who has been specifically recruited by Minara Coaching and is authorised to do so. Any such employee/partner will receive training on the requirements of GDPR before they are allowed to process personal data. They will only process personal data under my supervision and instruction and after they have signed a Confidentiality statement, agreeing not to share any information with a third party. A breach of this Confidentiality Statement will be deemed Gross Misconduct and will result in dismissal.
1 - Please be assured that I will never give your data to any third party organisation that wants to send you marketing communication.
2 - In due course, I will set up a mailing list which you may wish to subscribe to. I will only add you to my e mail list if you give explicit consent for me to do so.
3 - The data you provide during the sign-up process will be sent to Mailchimp which I will use to manage e mail marketing subscriber lists and to send e mails to my subscribers.
5 - If at any time after subscribing to the list, you decide you don't want to receive marketing communication from me, simply click on the 'unsubscribe' link which is included in every e mail. You will be removed from the subscriber list immediately.
6 - The lawful grounds for processing your personal data to send you marketing e mails is (i) your consent and (ii) legitimate interest to develop and grow the business. (You can remove consent by opting-out of receiving such e mails)
1 - I have developed a Consent Form which I will ask you to sign and date when you attend one of my workshops or coaching related activities.
2 - The Consent Form gives you the opportunity to tell me clearly whether or not I have your permission to:
i - process your personal, as well as, sensitive data
ii - e mail you about future workshops, coaching programmes and other coaching related activities
iii - use your testimonials or other feedback/evaluations for marketing purposes on my website and on social media
iv - add you to the closed Facebook group called The Minara Group
v - use any group photos in which you are included on my website or on social media.
3 - You are under no obligation to give permission and our professional relationship will not be affected if you don't consent to ii to v above. However, please do bear in mind that I can only provide a coaching service to you if you share personal information with me; so if you don't consent to me processing personal (and where necessary, sensitive) information, I won't be able to provide a service to you.
4 - If you do give consent to any of the above, you can change your mind at any time and withdraw consent. Please email me at firstname.lastname@example.org and I will amend my records accordingly.
1 - We do not sell, trade, or otherwise transfer to third parties your Personally Identifiable Information.
2 - While as a general rule we do not disclose your information to third parties, we may have to share your data with:
- IT and system administration service providers who assist us in operating our website
- professional advisers - eg - lawyers, insurers
- law enforcement agencies if we, in good faith, believe that a crime has been committed or if we suspect that someone is at risk of harm.
LINKS TO OTHER WEBSITES
I will only retain your personal data for as long as necessary.
For insurance purposes, I am required to keep Client Records for 5 years. After this period, paper documents are shredded and electronic data is deleted.
Under the GDPR you have certain rights with regards to the personal data we hold about you at Minara Coaching. These include:
- right to access - you have the right to view and obtain a copy of the personal data we hold about you
- right to rectification - you have the right to have any inaccuracies corrected
- right to erasure - you have the right to have your personal data removed from our records
- right to withdraw consent - where the lawful ground for processing data is Consent, you have the right to withdraw consent.
You can read more about your rights at:
Should you wish to exercise any of your rights under the GDPR, please e mail me at email@example.com
Please be aware that:
- As a security measure, we may need to request specific information to confirm your identity. This is to ensure that your personal data is not disclosed to an unauthorised third party.
- You will not normally have to pay to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if we consider that your request is excessive, repetitive or unreasonable. In such circumstances, we may also refuse to comply with your request. We will always give you a written reason for any such decision.
- We will normally respond to all legitimate requests within 1 month. If it is going to take us longer than 1 month to respond, we will keep in touch with you and explain the reason for any delays.
You also have the right to complain to the Information Commissioner's Office (ICO) if you have any concerns about how we process your personal data. The ICO is the UK supervisory authority for data protection matters. www.ico.org.uk
If you do have any concerns about how your personal data has been processed by Minara Coaching, please do approach me first by e mailing me at firstname.lastname@example.org so I can try and resolve your concerns.