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‘KingsCompass’ and ‘KingsCompass the Christian Coach Academy’ ™ are terms used interchangeably throughout this document as a trading name of ‘Carole Milligan Coaching & Consulting’, a sole trading practice committed to protecting and respecting your privacy. ‘Carole Milligan Coaching & Consulting’ trading as ‘KingsCompass’ (including ‘we’ ‘us ‘and‘our’) will only process personal data you provide to us in accordance with applicable privacy laws. The rules on processing of personal data are set out in the General Data Protection Regulation (‘GDPR’).
Carole Rutherford Milligan is our data protection officer and can be contacted at firstname.lastname@example.org
‘Data processor’ – is responsible for processing personal data on behalf of a data controller.
‘Data subject’ – a living individual. Anyone who is the subject of personal data.
‘Personal data’ – any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (see Article 6 of GDPR), for example name, home address, email address and online identifiers include IP addresses.
‘Processing’ – any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organising, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
‘Special categories personal data’ – as set out in the GDPR, the special categories specifically including genetic data, and biometric data where processed to uniquely identify an individual and other examples, include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
‘Third party’ – a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
If you are under 16 years.
We do not and will not knowingly collect information from any minor under the age of 16. If you are under the age of 16, you may not use our website unless you have the consent of, and are supervised by, a parent or guardian.
The purpose of processing your personal data
We use your personal data for the following purposes:
· Communicating with clients, students, alumni and those interested in our work with updates and news.
· Providing benefits, services and support to clients, students and alumni.
· Administration of courses and programmes.
· Developing our work (through research, partnerships, publications and fundraising).
The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal dataincluding, without limitation your:
· Email address
· Phone number
· Postal address
· Notes during the term of the coaching relationship.
· Log of coaching hours.
With respect to invoices and payments/receipts:
· Your/your organisation’s purchasing and financial payment details (as required by HMRC).
· Goods and services purchased.
We process special categories of dataincluding, without limitation:
· Any special learning needs.
· Dietary requirements.
We will also store, and use named testimonials, photographs and videos in our promotional material which includes (but is not limited to) our website, on and offline brochures and flyers, social media sites such as Facebook, Linked In, Twitter, Instagram and You Tube. We will only do this where we have obtained your consent which you may withdraw at any time by emailing email@example.com
The information we hold is obtained directly from information you have supplied by way of forms that you have filled in (such as contact forms, registration forms and invoices) or other written communication.
What is our legal basis for processing your personal data?
a) Personal data
We process your personal data in pursuit of our legitimate interest in fulfilling the purposes set out in ‘The categories of personal data concerned’ set out above.
Whilst we rely on legitimate interest as the legal basis for processing, where this is not overridden by the interests and rights or freedoms of the data subjects concerned, we recognise that it is not the only lawful ground for processing data. As such, where appropriate, we will sometimes process your data on an alternative legal basis – for example, because you have given us consent to do so, or to fulfil contractual obligations we may have when you request services from us.
We may also need to disclose your information to a third party if required by law (for example to government bodies and law enforcement agencies), including for the purposes of investigating a complaint, or if we have your permission to do so.
b) Special categories of personal data
To the extent we process your special categories of personal data, in addition to pursuing our legitimate interest in fulfilling the purposes set out in ‘The categories of personal data concerned’ set out above, we have obtained your explicit consent, or it may be necessary for reasons of public interest in the area of public health. (Further information on lawful processing can be found on the ICO website).
Sharing your personal data
Your personal data will be treated as strictly confidential.
We may though need or be required to disclose your information to a third party if required by law (for example to government bodies and law enforcement agencies) or where we have your permission to do so, for example, for the purposes of psychometric profiling such as DiSC, the Myers Briggs Type Indicator or similar or for example if making venue reservations in relation to participation in activity organised by us.
How long do we keep your personal data?
We keep your personal data only as long as is necessary for the purpose(s) for which it was collected (unless otherwise advised) and in accordance with our administrative records retention schedule and as required by HMRC. Data will be kept securely and destroyed when no longer required.
Providing us with your personal data
We require you to provide us with your personal data in order for us to fulfil the purposes set out in ‘The categories of personal data concerned’ described above.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data. The right to:
· Request a copy of the personal data which we hold about you.
· Request that we correct any personal data if it is found to be inaccurate or out of date.
· Request your personal data is erased where it is no longer necessary to retain such data.
· Withdraw your consent to the processing of your special categories of personal data at any time, where consent was the lawful basis for processing such data.
· Request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means).
· Request a restriction is placed on further processing, where there is a dispute in relation to the accuracy or processing of your personal data.
· Object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests or the performance of a task in the public interest/exercise of official authority), direct marketing and processing for the purposes of scientific/historical research and statistics).
Requests for your data to be removed or updated should be sent to: firstname.lastname@example.org
Hosted by Provider: Go Daddy
Our website hosting company processes data processed through the KingsCompass website, accessing this only on our instruction.
Maintained by: KingsCompass The Christian Coach Academy™
Our website development provider has access to the CMS part of the site, for support and maintenance purposes only. It does not process any of your data form the website.
Website e-commerce (course purchase)
Third-party providers: PayPal.
We use PayPal to process course payments through the website. These third-party providers are data processors for us and only process personal information in accordance with our instructions.
‘Zoom’ video conferencing and learning platform
Live on-line communication and learning sessions are enabled by our provider ‘Zoom’.
Where consent has been given these sessions will be recorded are stored on the Zoom ‘cloud’, our local hard drive and server. These are shared only with your consent (see above).
Not used on our website.
Third-party providers include (but are not limited to): Linked In, Facebook, Twitter, Instagram, You Tube, Vimeo.
If you send us a private or direct message via social media, the message will be stored by a third-party provider.
We monitor any emails sent to us for viruses or malicious software, including file attachments. Please be aware that you have a responsibility to ensure that any email you send is within the confines of the law.
Security and Performance
We use a third-party service to assist in maintaining the security and performance of our website, which requires the processing of website user’s IP addresses to do so. Whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us.
Automated Decision Making
We do not use any form of automated decision making.
How to Make a Complaint
We endeavour to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously and encourage individuals to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate, and welcome any suggestions for improving our procedures.
To exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Officer Carole Rutherford Milligan at: email@example.com
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on (local rate) or 01625 545 745 if you prefer to use a national rate number or via emailor at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
This policy was last updated 1stMay 2020