Privacy Policy
I am committed to ensuring that your personal data and privacy is protected. I understand how important and valuable your personal data is and I will only use it fairly and in ways that you would reasonably expect me to.
My contact details
Website address: https://www.sarahrichardscoaching.com
Sarah Richards Coaching is a trading name of Percipient Consulting Ltd. Percipient Consulting is a registered company in England and Wales, company registration number: 10585495
Company registered address:
72 Caerau Road
Newport, South Wales
NP20 4HJ
If you have any queries about how I use your personal data, you can contact me by emailing Sarah Richards at sarah@sarahrichardscoaching.com
How I use your personal data – the short version
I only collect the minimum personal data about you that I need to respond to you or work with you
I don’t keep personal data longer than I need to
You can opt out of receiving marketing information from me at any time
I will never share or sell your personal data for marketing purposes
I only share your personal data with trusted service providers or 3rd parties when I really need to and we will only share the minimum required
I take data protection very seriously and have appropriate security measures and safeguards in place to protect the personal data I collect
You can contact me with a query about your personal data at any time
What personal data we collect and why we collect it
What type of information we have
We may collect and process the following information:
- Contact details – Name, company name, email address, business address and telephone number
- Payment details – billing and payment details
- General information about your business activities and lifestyle choices
- Specific information about your coaching goals and desired outcomes including your progress against these goals.
We will only collect the minimum amount of personal data we need in relation to the purpose that we need it for.
Special Category (Sensitive) Personal Data
The following personal data is classed as Special category data under the GDPR and UK Data Protection Act 2018
- details about your ethnic or racial origin,
- political opinions,
- religious or philosophical beliefs,
- trade union membership
- genetic or biometric data,
- sexual orientation and sex life
- Medical and health data (including mental health)
I do not specifically request any of this personal data from you in order to provide coaching services, but from time to time you may choose to share information that is considered to be special category personal data with me during a coaching session. If it is appropriate to do so, I may make notes of the information you have shared in respect of how relevant it is to our coaching agreement and the coaching goals that we are working towards. I will however, only record in my notes the minimum amount of special category personal data relevant to the coaching conversation and the desired outcome for the session.
Under the UK GDPR there are special rules for processing Special Category personal data, I must have a lawful basis for doing so and must meet a specific condition of Article 9 of the UK GDPR – which is explicit consent.
If you decide to share special category personal data with me during a coaching session, it is with your explicit consent and my lawful basis for processing this personal data would be to fulfil our coaching contract.
How I get your personal data information and why we have it
Most of the personal information I process is provided to me directly by you for one of the following reasons:
- To request details and more information about the services I provide
- To sign up to my mailing list and receive regular communications about my services
- To provide coaching services, workshops or products to you
If any of your personal details change after you have provided them to us, please do let us know so that we can ensure our records are accurate and kept up to date.
Under the UK Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), we need to have a purpose and a lawful basis for processing your personal data. The lawful basis that I rely on are
- consent,
- performance of a contract,
- legitimate interests
- lawful basis.
Consent. If you are new to Sarah Richards Coaching and request our free downloads or to sign up to our mailing list, I will ask for your consent to contact you and add you to our database for marketing purposes.
Your consent can be withdrawn at any time, you can opt out of receiving our marketing information by either using the unsubscribe option on our emails or by contacting us at sarah@sarahrichardscoaching.com and asking to be removed from our mailing list.
When you opt out of receiving emails and marketing information from us, we will keep a minimum of data about you on our ‘do not contact’ list to ensure that we do not contact you further.
Performance of a contract: When you ask us to provide you with our coaching services, we will need to process your contact and billing data in order to deliver these services and perform our contract with you.
Legitimate Interests. If you contact us to request further information about our services, we will use your personal data to respond to your queries and our lawful basis will be legitimate interests. We also use legitimate interests to manage and conduct our business, this may include marketing activities and hosting events in order to grow our business. We may perform due diligence checks about your business before entering into a contract with you to provide our services.
When sending marketing information to Limited companies and Corporations, our lawful basis for processing your personal data for the purpose of contacting you is legitimate interests. You can opt out of receiving marketing communications from us at any time.
Under Privacy and Electronic Communications Regulations sole traders and partnerships are treated in the same way as consumers and your consent is required to receive marketing in electronic communications (including emails, direct messages and text messages) from us – unless you have previously done business with us or enquired about similar products or services and were given an option to opt out, but chose not to. If you have previously purchased or enquired about similar services from us and have not opted out of marketing communications, we will rely on Legitimate interests to continue to send you marketing communications. You can opt out of receiving marketing communications at any time.
When we use Legitimate Interests as our lawful basis for processing personal data, we will perform a Legitimate Interests balancing test and we will only use your personal data in a way that you would reasonably expect, ensuring that your rights and interests are protected.
If you have attended one of our coaching sessions or workshops or received any other services from us and provided feedback on the services provided, we may publish this feedback on our website, in marketing literature and on our social media channels in order to provide testimonials and help grow our business. We will not publish any identifying personal data in connection with any feedback you have provided without your consent.
Who I share your data with
I do not share or pass on your personal data to third parties for marketing purposes.
As a professional coach, I am committed to ongoing personal development and ensuring that my coaching practises are ethical and in line with best practise coaching standards set out by the International Coaching Federation (ICF) and the European Mentoring and Coaching Council (EMCC). This means that I undertake regular supervision with a coaching supervisor as well as working towards formal accreditation with a recognised coaching body.
I may confidentially share anonymised details of coaching sessions with my supervisor – this will not reveal your personal identity or reference you directly in any way that allows you to be identified. I also maintain a basic log of coaching hours which includes the name and email address for my coachees in order to work towards accreditation with the ICF. The purpose of this log is to demonstrate that I have recorded a specific number of coaching hours with an allocated number of coachees. Your name and email address will not be used for any other purpose by the accreditation bodies and will be treated confidentially.
I may share some details of your personal data with my trusted service providers and professional advisors, such as insurers, accountants and legal advisors only to the extent necessary for the purposes of processing my company accounts, meeting my legal obligations as a limited company and in the event of pursuing any insurance or legal claims.
In other words, I will only share the minimum amount of personal data necessary in these instances. I may also share your personal data with trusted service providers (such as email and cloud service hosting providers and payment processors). When doing so I expect these service providers and professional advisors to treat your personal data securely and only for the purposes intended.
In the unlikely event of non-payment of an invoice or legal dispute, I may share your personal data with 3rd parties in order to resolve and settle our dispute.
If and when required to do so by law, I may share elements of your personal data with appropriate Government Departments such as HMRC only to the extent necessary for the purposes of meeting my legal obligations as a limited company.
Where I store your data
Your information is stored on a secured computer network and cloud based software programs. I only use software and service providers who meet GDPR requirements and have the appropriate measures and security protocols in place to comply with UK and EEA data protection laws. All devices and equipment used to access and store your personal data have appropriate data security settings in place.
I have procedures in place to deal with data security breaches in accordance the UK Data Protection Act 2018.
How long I keep your data
I only keep personal data for as long as necessary in relation to the purpose it was collected for. When it is no longer required, I will dispose of your information by securely destroying the records we hold. In some instances I may anonymise data so that personal references are no longer kept.
I keep client records in accordance with UK statutory law and regulatory reporting timescales which is seven years.
I will keep names and email addresses for prospective clients on my mailing list for a maximum of two years.
Our “opt-out, do not contact list” is maintained for 2 years after which, all details will be removed.
What rights you have over your data
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal data in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at hello@sarahrichardscoaching.com if you wish to make a request.
How to complain
If you have any concerns or queries about our use of your personal information, you can contact us at sarah@sarahrichardscoaching.com
You can also complain to the ICO if you are unhappy with how we have used your data, but please do give us a chance to answer and resolve any queries with you beforehand.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Additional information
Embedded content from other websites
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These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Links to Other websites
We may have links on our site to other websites that we do not operate. If you click on a third party link, you will be taken directly to that site which is governed by its own privacy notice. We strongly encourage you to read that privacy notice. We do not control that site and assume no responsibility for the content, policies or its practices.
Cookies
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Analytics
Under Privacy and Electronic Communications regulations you have the right to agree to or reject non-essential cookies such as tracking and analytics cookies before they start doing their thing. We do not currently use any analytics or tracking cookies on this website. We will update this section when and if this changes.
This Privacy Policy was last updated on 5th September 2022.
