1. Personal Data
What is GDPR?
The General Data Protection Regulation is an EU regulation which applies from 25 May 2018. The GDPR affects all industry sectors and it addresses what we can and cannot do with your personal data. ‘Personal data’ is information that identifies individuals directly or from which individuals can be identified indirectly. Under the GDPR, we are the ‘data controller’ in relation to your personal data that we hold because we control the storage and use of that personal data.
Why this notice?
One of the requirements of the GDPR is that we let you know how we ‘process’ your personal data. ‘Processing’ includes obtaining, recording or storing personal data and carrying out any tasks using that personal data. This notice also describes your data protection rights, including your right to withdraw your consent for us to process your personal data.
Types of Personal Data
We hold personal data in the following categories:
- Clients – contact details, notes and correspondence
- Suppliers / contractors – contact details and correspondence
For what purposes does Compass Leading process personal data?
We process personal data because we deem it necessary for us to hold information about you and your circumstances in order to deliver the business coaching services we provide to you. Making and using notes of our coaching conversations is an integral part of how we work and allows us to be fully prepared for our sessions together. We process your personal data solely for the purpose of responding to any feedback you may send us and for providing our service to you and do not share it within our firm or with any other organisations other than with our technology suppliers or as required by law – for example, by court order, or to prevent fraud or other crime.
For suppliers / contractors
We process your data to allow us to work with you effectively. We do not share your data with any other organisations other than with our technology suppliers or as required by law – for example, by court order, or to prevent fraud or other crime.
What allows Compass Leading to process personal data?
Under the GDPR, the ‘lawful basis’ which allows us to process clients’ personal data is that it is in our ‘legitimate interest’ to do so – the processing is necessary for the performance of our service to you. This might also include providing you with a better service in the future, and building our relationship with you by sending you material in which you may be interested, including articles and links to reference materials written by us and by others.
We process supplier / contractor data because it is needed to ‘fulfil a contract’ with us.
What personal data does Compass Leading record and store?
In summary, we keep contact details and records of correspondence for clients and suppliers / contractors. In addition, we keep records of our coaching sessions with clients and these may include a variety of personal information, including (amongst other things):
- Your name, organisational title and email address(es) – but not your home postal address
- The names and organisational titles of your colleagues
- Your education and career history
How does Compass Leading process and store personal data?
We continue to be committed to protecting your personal information. Our aim is to maintain your trust and confidence in the way we handle your personal information whilst continuing to provide clients with a high quality coaching service, and suppliers / contractors with effective collaboration.
Compass Leading holds, centrally and in common, data limited to contractual and invoicing information. Individual Compass Leading coaches hold personal coaching notes electronically, password-protected and secure, and / or hand-written and printed notes stored securely.
We protect information held electronically through use of cyber security systems including firewalls, virus protection, and passwords; and hard copy information is stored securely.
For how long will Compass Leading keep personal data?
We have deemed that being able to provide you with support after the completion of our initial assignment, whether that be on an informal, unpaid basis or through further formal assignments, is part of our ‘service’ to you and your employers. Consequently, unless you instruct us not to, we will keep your personal data for as long as we feel it appropriate to be able to provide the service.
For suppliers / contractors
Similarly we will keep your personal data for as long as we feel it appropriate in order to facilitate our further working with you.
For clients and suppliers / contractors
The length of time we will keep your personal data will also reflect the obligations we have under applicable regulation to store personal data and the practicality of deleting or permanently anonymising your personal data.
‘Consent’ and your rights
Given the lawful basis which allows us to process your personal data (as described above), the GDPR does not require us to gain your explicit consent to that, only to let you know how we process it. However we are keen to ensure that you are happy with our approach. So if you decide, at any stage, that you would prefer us not to process your personal data, please contact your coach at Compass Leading.
You also have the right to:
- Be informed about the personal data we hold and why we hold it, (hence this notice).
- Access a copy of the data that we hold about you by contacting us directly.
- Check the information we hold about you is correct and to make corrections if not.
- Have your data erased in certain circumstances.
What can I do if I want to complain to you about Compass Leading’s use of my personal data?
Please contact your coach at Compass Leading if you want to complain about our use of your personal data. Alternatively, you have a right to lodge a complaint in relation to our processing of your personal data with a supervisory authority. The relevant supervisory authority is the Information Commissioner’s Office. The number for their helpline is 0303 123 1113.