PRIVACY AND DATA POLICY FOR PRIVATE CLIENTS
Mayler Management Coaching (MMC) is committed to being transparent about how it collects and uses the personal data of its contacts and clients, and to meeting its data protection obligations. This policy sets out our commitment to data protection and individual rights and obligations in relation to personal data.
This policy applies to the personal data of all contacts and clients for business purposes.
Nina Mayler has responsibility for data protection compliance within the Company. Questions about this policy of request for further information should be directed to her.
What information does MMC collect about you?
"Personal data" is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.
MMC collects and processes a range of information about you. This includes:
- Your name, address and contact details, including email address, skype address (and other relevant social media contact details), telephone numbers.
- Information relevant to the coaching and mentoring service being offered. This may include CVs, coaching session diary, notes, action plan, log and any mock interview scoring information.
- Evaluation feedback forms
MMC may collect this information in a variety of ways. For example, data might be collected through forms completed by you at the start of or during the contract; from correspondence with you; or through interviews, meetings or other assessments.
Data will be stored in a range of different places, including a hard copy client’s file, in MMC's management systems and in other IT systems (including a folder in Dropbox Professional, Back-up devices and the MMC's email system).
Dropbox is certified as being compliant with the most widely accepted security and privacy standards and regulations in the world, such as ISO 27001/2, ISO27018/17 and SOC 2.
Why does MMC process personal data?
Performance of Contract
MMC needs to process data to enter into a contract for management coaching and mentoring services with you and to meet its obligations under this contract. For example, it needs to process your data to provide you with a contract.
In some cases, the Company needs to process data to ensure that it is complying with its legal obligations. For example, it is required to comply with health and safety laws and meet it’s invoicing requirements for HMRC or respond to and defend any legal claims.
In other cases, MMC has a legitimate interest in processing personal data before, during and after the end of the contractual relationship. Processing client data allows MMC to maintain accurate and up-to-date client records and contact.
Who has access to data?
Your information may be shared internally within MMC for the purpose of invoicing.
MMC will not share your data with third parties apart from a sale of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.
How does MMC protect data?
MMC takes the security of your data seriously. The Company has internal controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed by anyone else. All data is kept secure, with access limited only to those who require the data for the proper performance of their role. All electronic personal data is password protected and hard copy files are kept secure in a locked cabinet to which only the Data Controller has keys.
For how long does MMC keep data?
MMC will hold basic personal contact details for a period of 6 years after the end of the contract for the purposes of HMRC compliance. The Company will hold your personal data that relates to the contracted piece of work for the duration of your contract plus a further period of six months post-contract.
What access do you have to your information?
As a data subject, you have the right to make a subject access request. You can:
- access and obtain a copy of your data on request;
- require the Company to change incorrect or incomplete data;
- require the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
- object to the processing of your data where the Company is relying on its legitimate interests as the legal ground for processing.
If you would like to exercise any of these rights, please contact Nina Mayler at firstname.lastname@example.org. We will ask for proof of identity before releasing your personal information to prevent unauthorised access.
If you believe that the Company has not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You have some obligations under your contract to provide the MMC with data. Certain information, such as contact details and payment details, have to be provided to enable the Company to enter a contract for services with you. If you do not provide other information, this will hinder MMC’s ability to administer the rights and obligations arising as a result of the contractual relationship efficiently.