Privacy policy

A coaching and mentoring relationship is built on Trust, Confidentiality, and Transparency. I am committed to ensuring that your personal data and privacy is protected. I understand how important and valuable your personal data is and will only use it fairly and in ways that you would reasonably expect us to.

This Privacy Policy explains:

• Who I am

• What personal data do I collect about you, and how I collect it

• Why I collect your personal data, and what I do with it.

• Sharing your personal data – Who I share it with

• How I retain your information and keep it secure

• Your rights and how to contact me

Who I am

Iain Holloway-McLean, owner, and director of IHM Coaching Ltd, registered in England under Company number: 14145355.

IHM Coaching Ltd is also registered with the Information Commissioner’s Office under registration number: ZB406412

The website address is: https://www.ihmcoachingcompany.co.uk

My registered address is: 67 Palmer Crescent, Leighton Buzzard, LU7 4HY

If you have any queries about how I use your personal data, you can contact me by emailing ihmcoaching@gmail.com

What Personal Data do I collect about you, and how I collect it

What personal data might I collect

I will only collect the minimum amount of personal data I need in relation to the purpose that I need it for. I may collect and process the following information:

• Your contact details – Name, address, email address, company name, business address and telephone numbers

• General information about your business/work activities and lifestyle choices, relationship status and dependents, shared by you during the course of our business services

• Specific information about your coaching or mentoring goals and desired outcomes including your progress against these goals.

• Payment details – billing and payment details

• Transaction history – details of products and services you purchase

• Technical data – IP address, general location, device type, browser type and version, operating system and platform, date and time of visit

• Usage data – information about how you use the website

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 or mentoring services, but from time to time you may choose to share information that is considered to be special category personal data during a 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 or mentoring goals that we are working towards. I will only keep a note or record of 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 our lawful basis for processing this personal data would be to fulfil our coaching contract.

How I collect your personal data.

Most of your personal data or information I collect and process is provided directly by you during or following one of the following reasons.

• When you contact me to request details and more information about the services I provide.

• When you contact me and ask me to provide you with a quotation.

• When you sign up to my mailing list to receive regular marketing communications about products and services.

• When you sign up to attend a workshop/masterclass/event I am hosting.

• When you enter a competition or complete a survey or a quiz

• When you purchase products / services

Additionally, I may receive your name and contact details from a 3rd party Coaching Organisation if you have registered with them to find a coach. I will use these details to contact you to find out more about your interest in coaching and to arrange a follow up discussion about working with me.

I may also collect technical data about you

• From automated technologies such as cookies*, pixels, web beacons and log files when you visit the website. This may include your IP address, your device type, operating system, browser type, time zone or general location and referring website.

• From third parties such as social media platforms when you interact with me on social media.

• Analytics service providers (such as Google Analytics) and search engine providers.

If any of your personal details change after you have provided them to me, please do let me know so that I can ensure our records are accurate and kept up to date.

* My website uses cookies as part of the user website experience. Cookies are small files saved to your computer’s hard drive that track, save, and store information about the user’s interactions and usage of the website.

Why I collect your personal data, and what I do with it

Under the UK Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), I need to have a purpose and a lawful basis for processing your personal data. I will only use your personal data for the purposes that I have collected it and in accordance with data protection law. This will be to:

• Provide a contract or service to you and manage our customer relationship

• When you have provided your consent – such as to receive marketing information from me

• When I have a legal obligation to do so – such as to comply with regulatory and statutory reporting

• When I have a legitimate business reason for doing so, such as to manage and grow my business, if you would reasonably expect me to do so and it does not impact on your rights, freedoms and interests.

When you visit my website

I use automated technology such as “cookies”, pixels, beacons and log files to collect information about how my website is used. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.

I do this to understand my visitor’s behaviour, preferences, and activities and to analyse and improve and update my content and services and to maintain the secure operation and running of my website

My lawful basis is my legitimate interests to

• manage my website and business,

• maintain my systems security and prevent fraud

• to manage my marketing and business activities and improve my services.

The data that I collect about you will depend on your cookie preferences and settings. For more information about how we use cookies please see our Cookie Policy [insert cookie policy]

When you sign up to receive marketing information

I will:

• Add your contact details to my email list /database

• Save your marketing preferences

• Send you my marketing information

• Record and keep a record of your consent to marketing

My lawful basis will be your consent. Your consent can be withdrawn at any time, you can opt out of receiving our marketing information by contacting me at ihmcoaching@gmail.com and asking to be removed from my mailing list. When you opt out of receiving emails and marketing information from me, I will keep a minimum of data about you on my ‘do not contact’ list to ensure that I do not contact you further.

Like many businesses I monitor open rates and interactions with my email marketing campaigns via automated technology within my email campaign software. Emails may contain a clear GIF simple web beacon. Web beacons are a small clear picture file that track whether a user has accessed the content.

I do this to understand how my subscribers interact with my email marketing campaigns and to help me improve what I send. The information that my email software collects is your IP address, country, the device, and browser type that you used to open an email. You can set your email client to display emails as text only or disable cookies in your browser before opening emails to remove and prevent your information being monitored in this way.

When you request further information about my products or services

I will

• Keep a record of and reply to your request for more information about my products or services

My lawful basis for doing this is because I have a legitimate business interest in responding to your queries and requests for information to manage and grow my business.

When you sign up to work with me and request my coaching or mentoring products or services

I will use your personal data to

• Register you as a client

• Manage our client relationship, respond to queries and communicate with you

• Provide the coaching products or service you have requested

• Send you an invoice/take payment for the coaching product or services you have requested

• I will maintain records and notes of our coaching sessions which may include general information about your business/work activities and lifestyle choices as well as specific information about your goals for coaching and your progress against these goals.

My lawful basis will be to perform a contract with you.

I keep client records and transaction history in order to comply with statutory and regulatory reporting requirements such as maintaining appropriate company records and business accounts and to meet my legal requirements. My lawful basis for doing so is my legal obligation.

Legitimate Interests:

I use legitimate interests to manage and conduct our business, this may include marketing activities and hosting events either online or in person to grow our business. I may perform due diligence checks about your business before entering into a contract with you to provide my services. If you have attended one of my events or received any other services from me and given me feedback or a testimonial about the services I provided, I may publish this feedback on my website, in marketing literature and on my social media channels to provide testimonials and help grow my business. I will not publish any identifying personal data in connection with any feedback you have provided without your consent.

Marketing

Under Privacy and Electronic Communications Regulations if you are a consumer, sole trader partnership your consent is required to receive marketing in electronic communications (including emails, direct messages, and text messages) unless you have previously done business with me or enquired about similar products or services.

If you have previously purchased or enquired about similar services from me and have not opted out of marketing communications, I will rely on Legitimate interests to continue to send you marketing communications. You can opt out of receiving marketing communications at any time by emailing me at ihmcoaching@gmail.com

When sending marketing information to Limited companies and Corporations, my lawful basis for processing your personal data for the purpose of contacting you is legitimate interests to grow and develop our business. You can opt out of receiving marketing communications from me at any time by emailing me at ihmcoaching@gmail.com

When I use Legitimate Interests as my lawful basis for processing personal data, I will perform a Legitimate Interests balancing test and I will only use your personal data in a way that you would reasonably expect, ensuring that your rights and interests are protected.

Sharing your personal data – Who I share it 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/maintaining formal accreditation with a recognised coaching body.

From time to time, 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 of my coachees in accordance with the International Coaching Federations accreditation requirements. 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.

If there is an occasion where I am required to share your personal data or details of our coaching sessions with 3rd party stakeholders such as a line manager, HR representative or senior management team, this will be clearly explained and agreed prior to our coaching taking place.

I may share some details of your personal data with my trusted service providers and professional advisors, such as insurers, accountants, and legal advisors. I do this 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. When doing so I expect these service providers and professional advisors to treat your personal data securely and only for the purposes intended. I will only share the minimum amount of personal data necessary in these instances.

My service providers (such as email and cloud service hosting providers, website hosting and payment processors) may have access to your personal data when it is stored on their systems. These service providers only have access to your personal data for the purpose of fulfilling their contract with me and will not use your personal data for their own purposes. When appropriate I have relevant data processing agreements in place with these service providers.

I may share some details of your personal data with our service providers such as virtual assistants and freelancers. When doing so I expect these service providers to treat your personal data securely and only for the purposes intended. These service providers only have access to your personal data for the purpose of fulfilling their contract with me and will not use your personal data for their own purposes.

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.

I may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

How I retain your information and keep it secure

How I store your personal information

Your information is securely stored on a secured computer network and cloud-based software programs. I only use mainstream software and service providers that 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 2018.5.2.

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 I hold. In some instances, I may anonymise data so that personal references are no longer kept.

I keep basic client records in accordance with UK statutory law and regulatory reporting timescales which is seven years. These include customer details, contact information, coaching log/hours, and transaction and payment history.

I keep detailed notes (and any recordings as per agreement in our contract) of our coaching sessions for two years after our coaching sessions have ended. After this time, wherever possible I anonymise our records to remove any of your identifying personal data but retain a summarised history of our coaching sessions to assist with ongoing accreditation to professional coaching bodies and my professional development as a coach.

I keep names and email addresses for prospective clients on my mailing list for two years

My “opt-out, do not contact list” is maintained for two years after which, all details will be removed.

Your rights and how to contact me

Under data protection law, you have the following rights:

• Your right of access - You have the right to ask me for copies of your personal information.

• Your right to rectification - You have the right to ask me to rectify personal information you think is inaccurate. You also have the right to ask me to complete information you think is incomplete.

• Your right to erasure - You have the right to ask me to erase your personal information in certain circumstances. If you have been a customer and purchased my products or services, I will not be able to delete all of your records as I have an obligation to retain some records for tax and accounting purposes.

• Your right to restriction of processing - You have the right to ask me to restrict the processing of your personal information in certain circumstances.

• Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

• Your right to data portability - You have the right to ask that I transfer the personal information you gave me 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, I have one month to respond to you. Please contact me at ihmcoaching@gmail.com if you wish to make a request.

How to complain

If you have any concerns or queries about my use of your personal information, you can contact me at ihmcoaching@gmail.com

You can also complain to the ICO if you are unhappy with how I have used your data, but please do give me a chance to answer and resolve any queries with you beforehand.

The ICO’s address is:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

Additional information

Embedded content from other websites

Articles on this website may include embedded content (e.g., videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. 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

I may have links on my site to other websites that I 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. I do not control that site and assume no responsibility for the content, policies or its practices.

Cookies

Cookies are small text files that are used to store small pieces of information. They are stored on your device when the website is loaded on your browser. These cookies help me make the website function properly, make it more secure, provide better user experience, and understand how the website performs and to analyse what works and where it needs improvement. As most of the online services, my website uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data. The third-party cookies used on my website are mainly for understanding how the website performs, how you interact with my website, keeping my services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with my website.

What types of cookies do I use?

• Essential: Some cookies are essential for you to be able to experience the full functionality of my site. They allow me to maintain user sessions and prevent any security threats. They do not collect or store any personal information.

• Statistics: These cookies store information like the number of visitors to the website, the number of unique visitors, which pages of the website have been visited, the source of the visit, etc. These data help me understand and analyse how well the website performs and where it needs improvement.

• Functional: These are the cookies that help certain non-essential functionalities on my website. These functionalities include embedding content like videos or sharing content of the website on social media platforms.

• Preferences: These cookies help me store your settings and browsing preferences like language preferences so that you have a better and efficient experience on future visits to the website.

If you would like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

You can find out more about cookies here: https://www.cookiesandyou.com

This Privacy Policy was last updated on 01 December 2022