1. How we use your personal data
1.1 Connecting Insight Limited (‘We’) (trading as Lucy Paltnoi), Company Number 07331933 England & Wales, with registered office address at Cullips House, 4 Nesbitts Alley, Barnet, Herts, England, EN5 5XG, is committed to protecting your personal data, as set out in this Privacy Notice. It is a condition of any coaching and/or complementary therapy consultations /treatments that you give your explicit consent to us documenting and processing your personal data in the manner described below, and in accordance with all applicable legislation.
1.2 The personal data we collect from you is as submitted by you by email, in response to questionnaire(s) and the data you provide us during telephone calls, by email or during coaching and/or complementary therapy consultations/treatments. Records and case notes of your consultations and our discussions will be kept, for efficient and careful practice.
1.3 We will use your non-sensitive personal data to (a) register you as a new client, (b) manage payment (c) in the provision of our services to you and to manage our relationship with you, for example, to send you appointment reminders or information concerning your consultations/treatments, (d) collect and recover monies owed to us where applicable, (e) send you details of our goods and services which we believe may be of interest to you and (f) if we promote other practitioners, who may not be connected to us in any way. Our legal grounds for processing your data in relation to points (a), (b), (c), (d) and (f) in this paragraph are for performance of a contract with you in the course of provision of coaching and/or complementary therapy consultations/treatments, and in relation to points (b), (c), (d), (e) and (f) as may be necessary for our legitimate interests to develop our products/services, to respond to enquiries relating to our services and grow our business and to recover monies owed.
1.4 We will use your sensitive personal data (that is data submitted by you which may include your personal information revealing detailed health information, racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic information, biometric information and information about sex life or orientation) by email, in response to questionnaire(s) and the data you provide us during telephone calls, by email or notes made during life coaching and/or complementary therapy consultations /treatments), for the purposes of providing our services to you or if we need to comply with a legal obligation. We will only collect what is relevant and necessary for your consultations/treatments. Our legal ground of processing this data is your explicit consent for us to do so, so that we can provide you with our services.
1.5 We will not share your details with third parties for marketing purposes except with your express consent. If we ask for your consent to use your personal information for marketing purposes you can take back this consent at any time. Any use of your information before you withdraw your consent remains valid. Please contact us if you would like to withdraw any consent given.
2. Disclosure of your personal data
2.1 We may have to share your personal data with (i) service providers who provide IT and system administration support, (ii) professional advisors including accountants, lawyers, bankers, auditors, insurers and/or in connection with the recovery of any unpaid fees (iii) HMRC and other regulatory authorities (iv) third parties to whom we sell, transfer or merge parts of our business or our assets, (v) to other professionals for the purposes of discussing your life coaching and/or complementary therapy consultation/treatment, (vi) to any relevant supervisory coach/training organisation, as part of training (and you will have been previously informed by us about such training) and/or (vii) to investigate, detect, prevent or mitigate any potential or actual fraud, security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
2.2 We require all such third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. They are only allowed to process your personal data on our instructions.
3. International Transfers
3.1 Some of our third party providers may be businesses outside of the EEA in countries which do not always offer the same levels of protection for your personal data. We do our best to ensure a similar degree of security by ensuring that contracts, code of conduct or certification are in place which give your personal data the same protection it has within Europe. If we are not able to do so, we will request your explicit consent to the transfer and you can withdraw this consent at any time.
4. Data security
4.1 We have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator where we are legally required to do so.
4.2 In certain circumstances you can ask us to delete your data. See the section entitled ‘your rights’ below for more information. We also may anonymise your personal data (so that you can no longer be identified from such data) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
5. Data retention
5.1 We will only keep your personal data for as long as is necessary to fulfil the purposes for which we collected it. We may retain your data to satisfy any legal, accounting, insurance, regulatory body or reporting requirements, so for example we need to keep certain information about you for at least 8 years, and may be retained indefinitely, after you cease to be a client in order to comply with legal guidelines. You have the right to ask us to delete the personal data we hold about you in certain circumstances. See section 6 below.
6. Your rights
6.1 You are able to exercise certain rights in relation to your personal data that we process. These are set out in more detail at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
6.2 In relation to a Subject Access Right request, you may request that we inform you of the data we hold about you and how we process it. We will not charge a fee for responding to this request unless your request is clearly unfounded, repetitive or excessive in which case we may charge a reasonable fee or decline to respond. Personal identification (in a form satisfactory to us, which may include a copy of your driving licence, passport, birth certificate and a utility bill with your home address on it dated in the last 3 months and which may include photographic ID) will be required from you when a Subject Access Right request is made. We will, in most cases, reply within one month of the date of the request unless your request is complex or you have made a large number of requests in which case we will notify you of any delay and will in any event reply within 3 months.
6.3 If you wish to make a Subject Access Request, please send the request by email to firstname.lastname@example.org, marked for the attention of Lucy Paltnoi.
7. Keeping your data up to date
7.1 Where we have a duty to keep your personal data up to date and accurate then from time to time we will contact you to ask you to confirm that your personal data is still accurate and up to date. If there are any changes to your personal data (such as a change of address) please let us know as soon as possible by emailing the address set out in section 6 above.
8.1 We are committed to protecting your personal data but if for some reason you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However we would be very grateful if you would please contact us first if you do have a complaint, so that we can try to resolve it for you in the first instance.
CONNECTING INSIGHT LIMITED, 2020