Oakley Coach is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to protecting the privacy and security of your personal information. This privacy notice describes, in line with GDPR, how we collect and use personal data about you during and after your time as a patient of this clinic. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
This notice applies to current and former clients.
Data controller details
Oakley Coach is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows:
2 Palmers Road
Oakley Coach’s Data Protection Officer is Rhiannon Oakley. She can be contacted on 07854625210.
Acorn Health is our data processor, a third party who provide physical premises for us to coach within and are responsible for booking coaching appointments. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it.
Data protection principles
In relation to your personal data, we will comply with data protection law. This says that the personal information we hold about you must be:
• processed fairly, lawfully and in a clear, transparent way
• collected only for valid reasons that we find proper for the course of your time as a client and not used in any way that is incompatible with those purposes
• only used in the way that we have told you about
• accurate and up to date
• kept only as long as is necessary for the purposes we outline
• process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed
• kept securely
Types of information we hold about you
Personal data or information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.
We hold many types of data about you, including:
- Your name, address, date of birth, email address and phone numbers.
- Banking or financial information used for booking of appointments online or purchasing products
- Information concerning your coaching sessions
- Voicemails that are left on our telephone system
- The content of letters and emails you send to us
- Information submitted through our website
- Cookie data
- Images supplied to us for use in our service delivery
Special categories of data
There are “special categories” of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation. During the course of your coaching sessions, it is possible some of this data may be discussed and recorded if pertinent to your coaching sessions. This may include details of your:
- Sex life
- Sexual orientation
- Ethnic origin
- Genetic and biometric data
We will use your special category data:
1. To ensure the coaching sessions are relevant to your needs.
2. To determine reasonable adjustments that should be made for access to our place of business or for your coaching sessions.
We must process special categories of data in accordance with more stringent guidelines. We will process special categories of data when the following applies:
• you have given explicit consent to the processing (on our initial contract forms)
• we must process the data in order to carry out our legal obligations
• we must process data for reasons of substantial public interest
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
How we collect your data
We collect data about you in a variety of ways and this will usually start when you make an enquiry to Oakley Coach and continue when you attend your first and subsequent coaching sessions. At Oakley Coach, we keep paper and electronic records. Information we write down on paper may be transferred to our electronic system.
Electronic data is stored on an encrypted, password protected laptop.
This data is accessible only to members of Oakley Coach staff who are directly involved in your care. We have implemented a two-tier security platform: Our receptionists can access your appointment booking information and billing details but have no access to your coaching notes. Your coach has full access to your account including booking information, billing details and clinical notes. This further helps to protect your data and minimises the ability of others to access your data. Our passwords are changed regularly, are unique to each staff member and are never shared between staff members.
Why we process your data (How we will use information about you)
The law on data protection allows us to process your data for certain reasons only, these are classified as legitimate interests. Most commonly, we will use your personal information in the following circumstances:
• in order for us to carry out our contract with you (your requesting coaching sessions and our agreement to provide it constitutes a contract) which will include confirming appointments, informing you of changes to appointments or session arrangements, changes to facilities or services at Oakley Coach.
• in order to provide you with the best possible coaching sessions by recording session information which would be in your best interest.
• in order to carry out legally required duties
• where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests
We may use your personal information in these rare situations:
• where we need to protect your or someone else’s interests
• where it is needed in the public interest or for official purposes
Situations in which we will use your personal information
We need all the categories of information to primarily allow us to perform our contract of treatment with you and to enable us to comply with legal obligations.
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out our duties in line with your coaching contract with us. If you do not provide us with the data needed to do this, we will be unable to perform that care to ensure your best interests are being maintained.
Change of purpose
We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Automated decision making
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
Sharing your data
Your data will be shared with colleagues within Oakley Coach but only where it is necessary for them to undertake their duties. This includes, for example, other coaches working for, at, or on behalf of the Oakley Coach and reception staff.
Third pArty Processor: WordPress
We use a third party service, WordPress.com, to publish our blog and website. These are hosted at WordPress.com, which is run by Automattic Inc. We use a standard WordPress service to collect anonymous information about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. WordPress requires visitors that want to post a comment to enter a name and email address. For more information about how WordPress processes data, please see Automattic’s privacy notice.
We may also share your data with third parties as part of a business sale or restructure, or for other reasons to comply with a legal obligation upon us. We would always keep you informed of these situations.
Third Party: E-newsletter
We use a third party provider, Mailchimp, to deliver our e-newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For more information, please see Mailchimp’s privacy notice.
Transferring information outside the EU
We do not share your data with bodies outside of the European Economic Area.
Data Security – Protecting your data
We have put in place measures to protect the security of your information against accidental loss or disclosure, alteration, unauthorised access, destruction or abuse. We have implemented processes to guard against such. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. This duty of confidentiality is available for you to view on request from reception.
Data Security Measures:
- All data from our computers is securely backed up and encrypted.
- Our computers are password protected. Our security protocols state that all passwords for computers are changed on a regular basis.
- Notes regarding your coaching sessions are anonymised and stored in a secure records room at Acorn Health. Access to this room is secure and is accessible only to clinic staff members who may require access to deliver your care or process details.
- Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of your being a coaching client with Oakley Coach. To determine any appropriate retention period for personal data beyond eight years we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.
Once we no longer have a lawful use for retaining your information, we will dispose of it in a secure manner that maintains data security.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your time as a patient with us.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you.
• the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request. Find out how to do this from reception or your practitioner.
• the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you can require us to correct it.
• the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice. We also must inform you of any changes to how we use your data.
• the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
• the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
• the right to portability. You may request transfer the data that we hold on you for your own purposes.
If you want to access your data, review, verify or correct your data, request we erase your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Rhiannon Oakley in writing at the address above.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee for a second or subsequent copy of information or if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
Where you have provided consent to the collection, processing and transfer of your data, you have the right to withdraw that consent at any time. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate legal reason for doing so.
To withdraw consent, contact Rhiannon Oakley.
Making a complaint
If you have any questions about this Privacy Notice or how we handle your information, please contact Oakley Coach’s Data Protection Officer, Rhiannon Oakley. She can be contacted on 07854625210.
You have the right to make a complaint at any time to the supervisory authority in the UK for data protection matters, the Information Commissioner’s Office (ICO).