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Hanwell Associates Ltd customer privacy notice

What information we collect, use, and why

 

We collect or use the following information to provide services and goods, including delivery:

  • Names and contact details

  • Purchase or account history

  • Payment details (including card or bank information for transfers and direct debits)

  • Health information (including dietary requirements, allergies and health conditions) 1

  • Health and safety information

  • Account information

  • Website user information (including user journeys and cookie tracking)

  • Call recordings

  • Records of meetings and decisions

  • Identification documents

  • Information relating to compliments or complaints

1 This will be unusual and such information will only be collected if a client makes a disclosure during a coaching session and this information is relevant in to support the client coaching experience. An example might be where a client has a health condition that impacts upon their ability to carry out their responsibilities and the coach is supporting them to manage this.

We collect or use the following information for the operation of customer accounts and guarantees:

  • Names and contact details

  • Payment details (including card or bank information for transfers and direct debits)

  • Purchase history

  • Account information, including registration details

  • Information used for security purposes

  • Marketing preferences

We collect or use the following information for service updates or marketing purposes:

  • Names and contact details

  • Marketing preferences

  • Location data

  • Purchase or viewing history

  • IP addresses

  • Website and app user journey information

  • Records of consent, where appropriate

We collect or use the following information for research or archiving purposes:

  • Names and contact details

  • Location data

  • Purchase or viewing history

  • IP addresses

  • Website and app user journey information

  • Personal information used for administration of research

  • Personal information used for the purpose of research

  • Records of consent, where appropriate

We collect or use the following information to comply with legal requirements:

  • Name

  • Contact information

Lawful Bases

Our lawful bases for collecting or using personal information to provide services and goods are: - Consent - Contract - Legitimate interest: We provide bespoke leadership coaching and professional development. Information that is collected in records of meetings will therefore vary from client to client depending upon their circumstances and development needs. However, information will only be retained where its retention will contribute positively to the client experience of coaching and professional development. Information will be stored securely and the benefit of collecting such information is greater than the risks as it will enable us to adapt our approach to the individual's needs. Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are: - Consent - Contract - Legitimate interest: We provide bespoke leadership coaching and professional development. Information that is collected in records of meetings will therefore vary from client to client depending upon their circumstances and development needs. However, information will only be retained where its retention will contribute positively to the client experience of coaching and professional development. Information will be stored securely and the benefit of collecting such information is greater than the risks, as it will enable us to adapt our approach to the individual's needs. Our lawful bases for collecting or using personal information for service updates or marketing purposes are: - Consent - Legitimate interest: As we provide a bespoke service, the collection of personal information will enable us to better target support to individuals. For example, it might enable us to recommend particular programmes or interventions that would support individual development needs. As information is all stored securely and special category information is not collected, risks to individuals is minimised. Our lawful bases for collecting or using personal information for research or archiving purposes are: - Consent Our lawful bases for collecting or using personal information for legal requirements are: - Consent - Contract - Legitimate interest: In some circumstances, it may be necessary to share information with external agencies - for example, to safeguard children, upon request from police or courts, or to alert the appropriate authorities of a criminal offence. All clients will be notified of the limits of confidentiality at the start of any relationship. Where we get personal information from: - People directly - Schools, colleges, universities or other education organisations - Publicly available sources

How long we keep information

Personal information is only retained for as long as it is required to provide the service. In practical terms this means for as long as the coaching relationship is “live”. As coaching sessions may be some time apart, it is necessary to retain information some time after each session. Personal information will be securely destroyed if a client has not engaged in any form of coaching or contact (e.g. by phone or online) for 12 calendar months. An exception to this is when a client writes a reference or recommendation for Hanwell Associates. Such references or recommendations will be retained indefinitely and may be displayed or shared publicly (e.g. on website, social media or upon request) until such time as a client requests they be removed or destroyed. Who we share information with Others we share personal information with: - Organisations we need to share information with for safeguarding reasons - Organisations we’re legally obliged to share personal information with Sharing information outside the UK: Where necessary, we may transfer personal information outside of the UK. An example of this is where digital information is stored using Cloud technology. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place. Please contact us for more information. Your data protection rights Under data protection law, you have rights including: Your right of access - You have the right to ask us for copies of your personal data. Your right to rectification - You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. Your right to erasure - You have the right to ask us to erase your personal data in certain circumstances. Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal data in certain circumstances. Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances. Your right to data portability - You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances. Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent. You don’t usually need to pay a fee to exercise your rights. If you make a request, we have one calendar month to respond to you. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

How To Complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.


If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.


The ICO’s address:           


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


Helpline number: 0303 123 1113


Website: https://www.ico.org.uk/make-a-complaint


Last updated: 19 July 2024

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