This privacy notice describes how Rosy Day Coaching ( Rosy Day Coaching - we) uses personal data relating to my coachees and those who enquire about coaching via my website.
We may update this notice from time to time. It was last updated on 18th November 2024
1. THE QUICK READ
Controller – Rosy Day Coaching: Rosy Day Coaching is a controller for use of your personal data, meaning it decides how and why your personal data is used.
Coachees: I may obtain your name, contact details and relevant background information from your organisation or from you directly. I will use your personal data to provide the coaching services. This may include notes made of the sessions with you, and other notes and communications relevant to these sessions. These may include sensitive information discussed during the sessions, such as data about your health, or racial or ethnic origin.
Sharing notes of sessions: I do not share personal data discussed in coaching sessions with your organisation or any other parties, except with your consent or in exceptional circumstances. Exceptional circumstances include where required by law, in order to protect you or someone else, or to protect our legal rights.
Coachees – additional records: Rosy Day Coaching will also hold information about you in order to keep records relevant to our relationship with your organisation (or you if you engage me directly). This includes your name, dates and times of sessions, payment information, and related communications. This information may be shared with your organisation.
Retention of data: I generally retain notes of our coaching sessions for 1 year. I generally retain other records containing your personal data for up to 7 years.
Our service providers: My service providers, including technology providers, may hold your data on our behalf (as processors) in providing their services to me.
International data transfers: I do not generally transfer your data outside the UK, except where you are outside the UK, or your organisation (or its head office) is located outside the UK, or to the extent our service providers have data centres outside the UK.
Your rights: You have rights in relation to our use of your data, including the right to access a copy of the data we hold about you, to withdraw any consent you have given, and, in certain circumstances, to object to our use of your data or request that we erase your data.
2. WHO I AM
For the purposes of data protection law, Rosy Day Coaching acts as a controller in our use of your personal data, meaning that I decide how and why I use your data.
You may contact Rosy Day Coaching with any queries or concerns about our use of your personal data, and to exercise your data protection rights. Email: rosy@rosydaycoaching.com
3. USE OF DATA ABOUT MY COACHEES
3.1 Referral from your organisation
You may be referred to me for coaching or supervision by your organisation, in which case your organisation will provide me with your name, job title, contact details, and background information about you and relevant to the coaching or supervision session.
3.2 Engaging me directly
If you engage Rosy Day Coaching directly for coaching or supervision services, I will collect information from you to provide these services, including your name, contact details, and background information relevant to the coaching or supervision sessions.
My legal basis under data protection law for using your data is that it is necessary for performing my services contract with you (or to take steps requested by you prior to entering into the contract).
3.3 Coaching sessions
I may make notes of your coaching sessions. This includes notes of matters discussed during the sessions, and other notes relevant to the sessions, such as themes and goals. They may include notes about sensitive matters which are discussed, such as information about your health, ethnic origin, beliefs or relationships with other people. I will also have records of any related emails or communications with you.
These notes and records assist me to provide my services effectively, and to ensure continuity between sessions, and they may be stored in paper or electronic form.
My legal basis under data protection law for using your data is that it is necessary in our legitimate interests in providing coaching services (or, if you engage us directly, that it is necessary for performance of our contract with you). I shall also seek your consent to making notes of any 'special categories of data' or data relating to criminal offences or convictions. Note: under data protection law, 'special categories of data' means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; genetic data, biometric data used for uniquely identifying you, and personal data concerning health, sex life or sexual orientation.
3.4 Accounts and records
Rosy Day Coaching will also hold information about you to keep accounts and records relevant to our relationships with your organisation (or with you, if you engage us directly). This information includes your name, dates and times of sessions and your attendance, associated payments, and other communications between us and your organisation or you relating to the coaching, training or supervision arrangements. This information may be shared with your organisation and, if requested by your organisation, with the organisation's head office (or other related entity) which is involved in the coaching, training or supervision arrangements.
My legal basis under data protection law for using and sharing this data is primarily that it is necessary in my legitimate interests in managing my relationships with your organisation (or with you if you engage us directly) . To the extent I share this data with your organisation's head office (or other related entity), my legal basis is that it is in the legitimate interests of your organisation in administering the coaching, training and supervision arrangements.
3.5 Other uses of your data
Your personal data may also be used by me to protect or enforce legal rights, or for other purposes permitted or required by law, including data protection law.
4. USE OF YOUR DATA IF YOU COMPLETE MY WEBSITE CONTACT FORM
If you contact me using the website contact form, I will use the information you provide to get in touch with you and respond to your query, and to keep appropriate records of enquiries (in my legitimate interests). If you are interested in receiving coaching services directly from us, we may request additional information about you and the services you are looking for, to arrange these services. See section 3.2.
5. SHARING YOUR DATA
5.1 Your Organisation
Relevant information about your coaching sessions (such as your attendance, and the dates and times) may be shared with your organisation who instructed us in relation to our services, and, in some cases, with its head office (see section 3.4).
Notes of coaching sessions will not generally be shared with your organisation (see section 3.3), except with your consent or in exceptional circumstances – see section 5.3.
5.2 Service providers
My service providers may handle your data, such as providers of email, document management and accounting systems. They act as processors on my behalf, meaning that I remain primarily responsible for how they use your data on our behalf in line with the purposes and legal bases identified in sections 3 to 4.
5.3 Other sharing of data
I may also share relevant personal data with the following parties: legal authorities or regulatory bodies, our legal or professional advisers or auditors, or other parties where I am required by law to do so (for compliance with a legal obligation, or otherwise in legitimate interests to protect or enforce our or their rights); other parties with your consent (for example if you give your consent to share certain notes of sessions with your organisation); and other parties where necessary to protect your rights and interests, or the rights or interests of another individual (in our legitimate interests, or for compliance with a legal obligation).
6. INTERNATIONAL DATA TRANSFERS
I do not generally transfer your data outside the UK except:
- where you are located outside the UK, in which case we or they may transfer data in communications with you; or
- where your organisation, or its head office (or other related entity) is located outside the UK.
I may transfer information such as your name, and dates and times of sessions, as described in section 3.4. Some countries or jurisdictions (such as the European Union) are covered by UK adequacy regulations, meaning that their data protection law is similar to that in the UK. If the country of transfer is not covered by UK adequacy regulations, I shall seek your consent to making such a transfer; or where our or their service providers have data centres or systems outside the UK.
7. RETAINING YOUR INFORMATION
I will retain your personal data for as long as I need it for the relevant purposes specified above, in accordance with my records retention procedures.
For coachees: notes of sessions (see section 3.3) are generally retained for 1 year from the conclusion of the coaching or supervision programme; and
other records relating to sessions (see section 3.4) are generally retained for 7 years or such other period as I may have agreed with any relevant service providers. My retention periods may be changed in appropriate circumstances, for example I may need to retain your details for longer if there is a relevant dispute or potential dispute. Please contact me (using the contact details at section 2) for additional information about retention periods and procedures.
8. YOUR DATA PROTECTION RIGHTS
Under data protection laws, you have certain rights in relation to our and our Associates' use of your personal data. These rights include the following:
- to obtain a copy of the personal data held about you, together with other information about how I use it (known as a subject access request);
- to withdraw any consent which you have given relating to the use of your data;
- to request rectification of inaccurate or incomplete data, and, in some circumstances, to request me to erase or restrict use of your data; where the legal basis for use of your data is legitimate interests (as specified in sections 3 to 5), to object to my processing of your data for reasons relating to your particular situation; to object to the use of your data for direct marketing purposes; where the legal basis for use of your data is your consent or necessity for my contract with you (as specified in sections 3 to 5), to exercise a right to data portability, in order to transfer sets of data provided by you and held electronically to another organisation; and not to be subject to a decision based solely on automated processing, which significantly affects you, unless additional legal requirements are met (although I do not make any such decisions as at the date of this notice).
Please contact Rosy Day Coaching (see section 2) to send requests to exercise your rights (specifying what you are requesting), or if you would like additional information about your rights. Note that there are certain limitations and exemptions to these rights which I may apply depending on the circumstances.
You may also make a complaint about how I handle your data to the UK Information Commissioner's Office. Please visit ico.org.uk for further information about how to do this (and further guidance on your rights). You may also take legal action in court to enforce your rights.