PRIVACY POLICY

This policy was last updated in January 2024 and is compliant with the provisions of the new GDPR ruling within the UK.

In this policy the use of, ‘we’, ‘us’, and ‘our’ refers to Compass Leading Limited, a company registered in England and Wales with company registration number 15082937, whose registered office address is at 3rd Floor, 12 Gough Square, London, EC4A 3DW (Compass Leading), and the use of ‘website’ refers to https://www.compassleading.com

This policy comprises three parts:

  1. Personal Data– how we collect, store, and use your personal information
  2. Website & Cookies– how we use cookies on our website
  3. Updates and Contact Information– how to get in touch

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?

For clients
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?

For clients
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.

2. Website & Cookies

This section sets out how Compass Leading uses and protects any information that you give us when you use this website. Compass Leading is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this overall privacy policy.

What we collect

We collect anonymous data relating to the use of this website. We don’t collect any information that can identify any individual.

Cookies

‘Cookies’ are small text files that are stored by the browser (e.g. Internet Explorer, Chrome or Firefox) on your computer or mobile phone. They allow websites to store such things as user preferences. You can think of cookies as providing a ‘memory’ for the website, enabling it to recognise a user and respond appropriately.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Anonymous analytics cookies

Every time a user visits our website, web analytics software provided by a third party generates an anonymous analytics cookie. These cookies can tell us whether or not you have visited the site before. Your browser will tell us if you have these cookies, and if you don’t, we generate new ones. This allows us to track how many individual unique users we have, and how often they visit the site. Some browsers, such as Internet Explorer or Firefox, will allow you to opt out of receiving these cookies.

Third-party cookies

On some pages of the compassleading.com website third parties may also set their own anonymous cookies for the purposes of tracking the success of their application, or customising the application for you. Because of how cookies work, Compass Leading cannot access these cookies, nor can the third parties access the data in cookies used by Compass Leading. For example, if you share an article using a social media sharing button on Compass Leading’s website, the social network that has created that button will record that you have done this by setting a cookie.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

3. Updates & Contact Information

We may update this notice from time to time to reflect changes in the way we process your personal data or to clarify information we have provided in this notice. Any changes will be lodged on our website and we will notify you directly about any we think are significant or when we are legally required to do so.

If you have any queries regarding this Privacy Policy, or if you would like to exercise your rights as stated above, you may contact us at coaching@compassleading.com or by post at 3rd Floor, 12 Gough Square, London, EC4A 3DW.

Compass Leading
January 2024