Registered Organsiations

When we handle personal data, we must abide by a number of principles and respect certain rights that individuals have regarding their Personal Data. ‘Personal data’ means any information relating to a person. In our contact with you, we may collect data through our website, via email, an online portal or verbally. ‘Handling’ involves any operation where we collect, record, organise, alter, transmit or destroy personal data. 

These Guidelines set out how Impact Coaching Support, registered in England and Wales No:  14846824  uses and protects any information that you provide when engaging with our services or using our website. We are committed to protecting your privacy and we comply with the UK Data Protection laws and are registered with the Information Commissioner’s Office. (Registration No: ZA331784). 

We place high priority on safeguarding confidential information and processing personal data and take our responsibility for security of your data seriously. When we handle personal data, we abide by a number of principles and respect individual rights to comply with the EU GDPR. 

The 6 key Data Protection Principles are:

1. Lawfulness, Fairness and Transparency – we only use personal data in ways you would reasonably expect e.g. to process payments, contracts, to meet legal obligations, carry out our contract with you, and with your freely given consent.
2. Purpose limitation – we only collect personal data for specified, explicit and legitimate purposes.
3. Data minimisation – we ensure our use of personal data is adequate, relevant and necessary and keep the minimum amount of personal data to fulfil our purposes.
4. Accuracy – we do our best to ensure data is accurate and up to date.
5. Storage limitation – we do not keep data for longer than is necessary, reviewing periodically when and why we keep data, and securely deleting information no longer needed, in line with UK regulatory guidance e.g. tax records.  All Data is held in the United Kingdom. We do not store personal data outside the EEA. All data storage services used are fully GDPR compliant and available on request. How long is information stored for- data retention? Your information is kept for the time necessary to provide the  service requested, however outside of this, we will hold your details and any session notes for a period of 7 years following the end of our service to comply with legal obligations that are placed upon us by our insurers.
6. Integrity and Confidentiality – we have taken every reasonable step to ensure that your personal data is held securely at all times and use security measures to protect our systems. We ensure that personal data is processed and held securely, using secure servers, password protected and encryption of sensitive documents. Please be aware that no internet or email transmission is ever fully secure or error free, and we ask you to take special care in deciding what personal data you send to us via email or disclose via the internet. 

Use of Google Analytics

 When someone visits this website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way, which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. 

What Data Is Collected and How it is Used?

Impact Coaching Support are pleased to provide the following information:

We are qualified professionals and approach our work with the utmost regard for a client’s wellbeing and rights.  The British psychological Society (BPS) regulate and inform our practice. You can find out more about our professional and legal responsibilities on their website.
www.bps.org.uk

Information collected about you and how we use it....

1. Initial contact (or chemistry session) will be to ascertain the goals and needs of coaching either for an individual or organisation.  This means basic organisational information will be shared and collected.  If working with an individual basic personal information will be collected for contact and identification reasons.  This data will form the basis of a terms of reference of contract and will also include confidentiality clauses.  You will be told what tools are used to collect your data and how notes are made.  At this point you will be asked for your consent to collect this data and this will be recorded on our client management system.  Consent can be removed at any time and this will form the basis of the cancellation of any future sessions, which is under no obligation of payment, as long as given notice within 48 hours before the next session.  

As part of the information processing a contract will be signed that details; the values of the coach and practices used, confidentiality, when working with children the contract will be signed by the parent or carer/legal guardian, safeguarding statement will be included within the contract for children and the cost of the coaching sessions, along with contractual arrrangements for paying. 

2. During our coaching meetings, various types of work will take place and session notes will be taken to inform the coach of next steps, and solely to ensure a quality coaching service is provided. These notes are kept in line with GDPR and as previously stated retained for 7 years.  These may include personal and sensitive details about your life that may have been disclosed or sensitive data disclosed about the organisation. 

3.  Review, evaluation and assessment notes may be included in the session notes to ascertain impact of the coaching and provide details of work completed.

4.  A Coaching Report - can be asked for as a summary of the work, however this will not include the private session notes of the coach but will include the goals of the sessions, a summary of the work undertaken and an agreed impact/next steps statements.

Confidentiality

The information about confidentiality in no way contravenes  the General Data Protection Regulation May 2018 to access personal data that is held. Confidential records and statistics are kept all clients. Information but not names will be shared with a supervisor who is also accredited and who regularly reviews practice.
These records are subject to the General Data Protection Regulation May 2018. Personal and sensitive data will only be used in order to provide the  coaching service  and for managing and quality assuring the service.

Coaching is a private and confidential form of help. This means we will not normally give your name or any information about you to anyone outside the organisation. However, there are exceptional cases where  ethically or legally we have to give information to relevant authorities, for example if we had reason to believe that someone, especially a child or adult, is at serious risk of harm or to prevent a miscarriage of justice. All proposed discolsures will be  discussed  unless we believe that to do so could increase the level of risk to you or to someone else. There are other supervening legal and ethical obligations, such as our duty to comply with criminal investigations when legally obliged to do so.  When working with children or vulnerable adults our safeguarding duty should be noted as the statement below:

  'Joanne Kiernan has up to date Safeguarding Training which relates to documentation contained within    Keeping Children Safe in Education and Working Together to Safeguard Children as part of this training and professional accountability Joanne Kiernan will abide by the guidance given to schools and colleges for children under the age of 18 years or vulnerable adults.  Joanne Kiernan has an Enhanced DBS with the Update Service and this can be checked by following the Status Check Link.  Where there are indicators that fit within the definitions of abuse, or abuse is suspected, Joanne Kiernan will have an open conversation about this and will use local reporting procedures to Children’s Social Care or Adult Social Care.  Safeguarding duty requires me to breach confidentiality agreements made as part of this contract because I have concerns of harm. I am committed to offering good practice as a professional coaching psychologist and this is also a prerequisite for professional indemnity and liability.'

As a fully accredited member of the  BPS, we adhere to their ethical framework and guidelines to ensure that you receive a professional and quality service.

Your rights

We recognise that on rare occasions clients may wish to exercise their rights under the General Data Protection Regulation May 2018 and make a subject access request in respect of their personal information held. You have rights relating to the information held to verify the accuracy or to ask for them to be supplemented, deleted, updated or corrected. You have the right to request a copy of the information that is held about you or your organisation. If at any time you wish to exercise your right under the Act you should put your request in writing  and provide evidence of your identity such as a copy of your passport or driver’s license and proof of your address. When we receive evidence of identity we will respond to your request within 30 calendar days. Our response to a valid subject access request will normally be in the form of a schedule listing and describing the personal data held. You have a right to request the transfer of your data to another individual or company. We want to make sure that your information is accurate and up to date. You may ask me to correct or remove information you think is inaccurate. You have a right to request the transfer of your data to another individual or company.

Lawful basis for processing your information

The lawful basis for our holding and using your information is in relation to the delivery of a contract to you as a coaching professional.

Cancellation policy

If you intend to cancel, at least 48 hours’ notice should be given to avoid cancellation charges. If less than 48 hours notice is provided, you will be charged the full cost of your session to cover the incurred costs.

Feedback and complaints

If you have any feedback about the service you receive from me, or you are not satisfied with your experience, please contact us. It is possible that we can resolve your complaint and we welcome feedback and if you make a complaint, it will always be taken seriously as it allows us to improve the service that we can offer to others.

For further information or you wish to make a complaint please contact:

Name: Joanne Kiernan (Managing Director and Data Protection Representative)
Full Address: 9 Oaklands Terrace, Kirby Road, Hemsworth, West Yorkshire, WF9 4TX.

ICO
Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 https://ico.org.uk

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