GDPR PRIVACY STATEMENT
Data controller (“Connect2TVCoaching”):
Georgina Bobb at Connect2TVCoaching Tel: 07912345235 e: firstname.lastname@example.org
Connect2TVCoaching collects and processes personal information, or personal data, relating to its clients and those who give consent, web visitors and customers who submits their CV and send a message via our website, purchases a training programme or purchases our online course. This personal information may be held by Connect2TVCoaching on paper or in electronic format.
Connect2TVCoaching is committed to being transparent about how it handles your personal information, to protecting the privacy and security of your personal information and to meeting its data protection obligations under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018. The purpose of this privacy notice is to make you aware of how and why we will collect and use your personal information both during and after your working relationship with Connect2TVCoaching. We are required under the GDPR to notify you of the information contained in this privacy notice.
Connect2TVCoaching has appointed a Georgina Bobb to oversee compliance with this privacy notice. If you have any questions about this privacy notice or about how we handle your personal information, please contact Georgina Bobb; 07912345235, email@example.com
Data protection principles
Under the GDPR, there are six data protection principles that Connect2TVCoaching must comply with. These provide that the personal information we hold about you must be:
- Processed lawfully, fairly and in a transparent manner.
- Collected only for legitimate purposes that have been clearly explained to you and not further processed in a way that is incompatible with those purposes.
- Adequate, relevant and limited to what is necessary in relation to those purposes.
- Accurate and, where necessary, kept up to date.
- Kept in a form which permits your identification for no longer than is necessary for those purposes.
- Processed in a way that ensures appropriate security of the data.
Connect2TVCoaching is responsible for, and must be able to demonstrate compliance with, these principles. This is called accountability.
What types of personal information do we collect about you?
Personal information is any information about an individual from which that person can be directly or indirectly identified. It doesn’t include anonymised data, i.e. where all identifying particulars have been removed. There are also “special categories” of personal information, and personal information on criminal convictions and offences, which requires a higher level of protection because it is of a more sensitive nature. The special categories of personal information comprise information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and genetic and biometric data.
On receipt of purchase or contact with Connect2TVCoaching, Connect2TVCoaching collects, uses and processes personal information about you. This includes (as applicable):
- your contact details, including your name, address, telephone number and personal e-mail address*
- personal information included in a CV, cover letter, references,
- training records including feedback form information if completed by yourself
- photographs and video clips, if in attendance of our training days or events.
How do we collect your personal information?
Connect2TVCoaching may collect personal information about you in a variety of ways. It is collected via mailing list bar on our website, through an event where you provided us with your contact details, by email, via Eventbrite and Hiive if contacted or purchased a ticket to one of our training days or events Thinkific via email receipt of online course purchased or Calendly on booking a coaching session.
Whilst some of the personal information you provide us has a legitimate business interest so that we can continue to keep you updated with new products and services, some of it you may be asked to provide to us on a voluntary basis. We will inform you whether you are required to provide certain personal information to us or if you have a choice in this.
Your personal information may be stored in Connect2TVCoaching’s management system which includes an encrypted file in a cloud storage system on a password protected IT system, a locked document safe and an email system.
Why and how do we use your personal information?
We will use your personal information in one or more of the following circumstances:
- where we wish to update you with products and services
- where we need to comply with a legal obligation
- where it is necessary for our legitimate interests (or those of a third party), and your interests or your fundamental rights and freedoms do not override our interests.
We need all the types of personal information listed under “What types of personal information do we collect about you?” primarily to enable us to perform our contract with you and to enable us to comply with our business obligations. In some cases, we may also use your personal information where it is necessary to pursue our legitimate interests (or those of a third party), provided that your interests or your fundamental rights and freedoms do not override our interests. Our legitimate interests include: performing or exercising our obligations or rights under the direct relationship that exists between Connect2TVCoaching and you as its customer;
The purposes for which we are processing, or will process, your personal information are to:
- enable us to maintain accurate and up-to-date customer records
- to update your CV or cover letter accordingly
- to provide you with only the information you need
- to tailor our products to your exact requirements
Please note that we may never process your personal information without your consent.
When you provide us with personal information to complete a transaction, place an order, or sign up to our company, we imply that you consent to our collecting it and using it for that specific reason only.
If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at firstname.lastname@example.org.
What if you fail to provide personal information?
If you fail to provide certain personal information when requested or required, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations. You may also be unable to exercise your statutory or contractual rights.
Change of purpose
We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for a purpose other than that for which it was collected, we will provide you, prior to that further processing, with information about the new purpose, we will explain the legal basis which allows us to process your personal information for the new purpose and we will provide you with any relevant further information. We may also issue a new privacy notice to you.
Who has access to your personal information?
Your personal information may be shared internally within Connect2TVCoaching, including with members of the marketing team.
Connect2TVCoaching may also share your personal information with third-party service providers including:
- external marketing professionals including Elizabeth Puddicombe
- external trainers and facilitators including Sinitta Monero, Pamella Bisson and Ash Greenwood.
- professional advisers, such as lawyers and accountants.
Connect2TVCoaching may also share your personal information with other third parties in the context of a potential sale or restructuring of some or all of its business. In those circumstances, your personal information will be subject to confidentiality undertakings.
We may also need to share your personal information with a regulator or to otherwise comply with the law.
We may share your personal information with third parties where it is necessary to administer the contract we have entered into with you, where we need to comply with a legal obligation, or where it is necessary for our legitimate interests (or those of a third party).
How does Connect2TVCoaching protect your personal information?
Connect2TVCoaching has put in place measures to protect the security of your personal information. It has internal policies, procedures and controls in place to try and prevent your personal information from being accidentally lost or destroyed, altered, disclosed or used or accessed in an unauthorised way. In addition, we limit access to your personal information to those designated staff and other third parties who have a business need to know in order to perform their job duties and responsibilities.
Where your personal information is shared with third-party service providers, we require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with data protection law. We only allow them to process your personal information for specified purposes and in accordance with our written instructions and we do not allow them to use your personal information for their own purposes.
Connect2TVCoaching also has in place procedures to deal with a suspected data security breach and we will notify the Information Commissioner’s Office (or any other applicable supervisory authority or regulator) and you of a suspected breach where we are legally required to do so.
For how long does Connect2TVCoaching keep your personal information?
Connect2TVCoaching will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal or accounting requirements.
Connect2TVCoaching will generally hold your personal information for the duration of your engagement. The exceptions are:
- 30 day deletion policy for CV’s and cover letters received and delivered to clients under Connect2TVCoaching.
- any personal information supplied as part of the recruitment process will not be retained if it has no bearing on the ongoing working relationship
Personal information which is no longer to be retained will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy or erase such personal information where applicable.
Your rights in connection with your personal information
It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes, e.g. you change your email address, during your working relationship with Connect2TVCoaching so that our records can be updated. Connect2TVCoaching cannot be held responsible for any errors in your personal information in this regard unless you have notified Connect2TVCoaching of the relevant change.
As a data subject, you have a number of statutory rights. Subject to certain conditions, and in certain circumstances, you have the right to:
- request access to your personal information – this is usually known as making a data subject access request and it enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it
- request rectification of your personal information – this enables you to have any inaccurate or incomplete personal information we hold about you corrected
- request the erasure of your personal information – this enables you to ask us to delete or remove your personal information where there’s no compelling reason for its continued processing, e.g. it’s no longer necessary in relation to the purpose for which it was originally collected
- restrict the processing of your personal information – this enables you to ask us to suspend the processing of your personal information, e.g. if you contest its accuracy and so want us to verify its accuracy
- object to the processing of your personal information – this enables you to ask us to stop processing your personal information where we are relying on the legitimate interests of the business as our legal basis for processing and there is something relating to your particular situation which makes you decide to object to processing on this ground
- data portability – this gives you the right to request the transfer of your personal information to another party so that you can reuse it across different services for your own purposes.
If you wish to exercise any of these rights, please contact us. We may need to check your right to access the personal information or to exercise any of your other rights. This is a security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This will not, however, affect the lawfulness of processing based on your consent before its withdrawal. If you wish to withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose you originally agreed to, unless we have another legal basis for processing.
If you believe that Connect2TVCoaching has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner’s Office (ICO) at any time. The ICO is the UK supervisory authority for data protection issues.
Changes to this privacy notice
Connect2TVCoaching reserves the right to update or amend this privacy notice at any time, including where Connect2TVCoaching intends to further process your personal information for a purpose other than that for which the personal information was collected or where we intend to process new types of personal information. We will issue you with a new privacy notice when we make significant updates or amendments. We may also notify you about the processing of your personal information in other ways.
If you have any questions about this privacy notice or how we handle your personal information, please contact our [data protection officer] as follows: Georgina Bobb, 07912345235, email@example.com