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WOMBA Ltd May 2018
We are a Data Controller under the terms of the Data Protection Act 2017 and the requirements of the EU General Data Protection Regulation.
This Privacy Notice explains what Personal Data the organisation holds, why we hold and process it, who we might share it with, and your rights and freedoms under the Law.
Types of Personal Data
WOMBA holds personal data in the following categories:
- Client notes and correspondence
- Staff employment data
- Suppliers /contractors data
Why we process Personal Data (what is the “purpose”)
“Process” means we obtain, store, update and archive data.
- Client data is held for the purpose of providing clients with appropriate, high quality, and effective coaching.
- Staff employment data is held in accordance with Employment, Taxation and Pensions law.
3. Suppliers / contractors data is held for the purpose of good management and to maintain any contracts.
What is WOMBA’s Lawful Basis for processing Personal Data?
The Law says we must tell you this:
- We hold clients’ data because it is in our Legitimate Interest to do so. Without holding the data we cannot work effectively.
- We hold staff employment data because it is a Legal Obligation for us to do so.
- We hold suppliers’ data because it is needed to Fulfil a Contract with us.
Who might we share your data with?
We can only share data if it is done securely and it is necessary to do so.
- Client data may be shared with other professionals who need to be involved in your coaching (for example if we seek advice from coaching supervisors or academics about the most effective coaching interventions for your progress). Client data is also securely stored for back-up purposes with our computer software supplier.
- Employment data will be shared with government agencies such as HMRC.
You have the right to:
- Be informed about the personal data we hold and why we hold it.
- Access a copy of your data that we hold by contacting us directly: we will acknowledge your request and supply a response within one month or sooner.
- Check the information we hold about you is correct and to make corrections if not
- Have your data erased in certain circumstances.
- Transfer your data to someone else if you tell us to do so and it is safe and legal to do so.
- Tell us not to actively process or update your data in certain circumstances.
How long is the Personal Data stored for?
- We will store client data for as long as we are providing coaching support or because you opted in to being on our mailing list. We will archive your data (that is, store it without further action) for as long as is required for legal purposes.
- We must store employment data for six years after an employee has left.
- We must store contractors’ data for seven years after the contract is ended.
What if you are not happy or wish to raise a concern about our data processing?
You can complain in the first instance to our data protection office Helen Sachdev firstname.lastname@example.org and we will do our best to resolve the matter. If this fails, you can complain to the Information Commissioner at www.ico.org.uk/concerns or by calling 0303 123 1113.