Who we are
How we collect information about you
Information we collect and why we use it
Profiling: making our work more unique to you
Legal basis for using your information
Sharing your Information
Keeping your information safe
How long we hold your information for
1. Who we are
At The Empathy Coach, we are committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner.
We are a “data controller” for the purposes of the Data Protection Act 1998 and (from 25 May 2018) the EU General Data Protection Regulation 2016/679 (“Data Protection Law”). This means that we are responsible for, and control the processing of, your personal information.
For further information about our privacy practices, please contact our Data Protection Officer by:
Emailing us at firstname.lastname@example.org
2. How we collect information about you
Everything we do, we do to ensure that we can help people with learning or well-being needs get both support and respect. We want to make sure you receive the communications that are most relevant to you, be it through visiting our website or receiving emails, post or phone calls. We want to make sure you receive the best attention when you attend our learning and coaching sessions.
We collect information from you in the following ways:
When you interact with us directly: This could be if you ask us about our activities, register with us for training, coaching or an event, ask a question about our services, purchase something, apply for a job or volunteering opportunity or otherwise provide us with your personal information. This includes when you phone us, visit our website, attend sessions, commission our services, or get in touch through the post, or in person.
When you interact with us through partners or suppliers that commission our services: This could be if you attend sessions with us as an employee or referral of another organisation, such as your employer, school, community centre, charity partner, public service or local authority.
When you visit our website: We gather general information which might include which pages you visit most often and which services, events or information is of most interest to you. We may also track which pages you visit when you click on links in emails from us. We also use “cookies” to help our site run effectively. There are more details below – see ‘Cookies’.
We sometimes use this information to personalise the way our website is presented when you visit to make improvements and to ensure we provide the best service and experience for you. Wherever possible we use anonymous information which does not identify individual visitors to our website.
From other information that is available to the public: In order to tailor our communications with you to your background and interests we may collect information about you from publicly available sources or through third party subscription services or service providers (we have provided further details about this below – see ‘Profiling: Making our work unique to you’).
3. Information we collect and why we use it
Personal information we collect includes details such as your name, date of birth, email address, postal address, telephone number, bank and credit/debit card details (if you are making a purchase), as well as information you provide in any communications between us. You will have given us this information whilst enquiring about or registering for an event, attending events and sessions or any of the other ways to interact with us.
We will mainly use this information:
To process your payments.
To provide the services or goods that you have requested.
To update you with important administrative messages about your event, services or goods you have requested.
To provide you with additional information or supporting materials pertaining specifically to the service you have received from us.
To keep a record of your relationship with us.
If you do not provide this information, we may not be able to sign you up for a particular event or provide goods and services you have requested.
We may also use your personal information:
To contact you about our work and how you can support The Empathy Coach (see section 8 on ‘Marketing’ below for further information).
To invite you to participate in surveys or research.
Sensitive Personal Information
Any and all client notes we take pertaining to coaching sessions will be treated with strictest confidence. All sensitive client material is stored on secure cloud databases and password protected PCs and is backed up real-time.
A special note about the Sensitive Personal Information we hold
Data Protection Law recognises that some categories of personal information are more sensitive. Sensitive Personal Information can include information about a person’s health, race, ethnic origin, political opinions, sex life, sexual orientation or religious beliefs.
If you access any of our coaching services you may choose to provide details of a sensitive nature.
We will only use this information:
For the purposes of providing the highest standard of care, training, and quality monitoring or evaluating the services we provide.
We will not pass on your details to anyone else without your express permission except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or posing a threat to others or children contacting us and sharing serious issues such as physical abuse or exploitation.
Where you have given us your express consent or otherwise clearly indicated to us (for example, by submitting a testimony for our website) that you are happy for us to share your story, then we may publish it on our blog or in other media.
4. Profiling: making our work more unique to you
We want to improve how we talk to you and the information we provide through our website, services, products and information. To do this we sometimes use profiling and screening methods so that we can better understand our customers, your preferences and needs to provide a better experience for you.
We may offer targeted activities and services using profiling techniques based on the information that we hold about you. We may also work with third party organisations who provide additional insight, this may include providing wealth screening information or general information about you that is publicly available.
This information can be appended to the information that you have provided which allows us to use our resources more effectively by better understanding the background of our customers and making appropriate requests based on what may interest them and their capacity to commission or pay.
You can of course opt out of this activity at any time. To do this, email email@example.com with the subject line ‘Please stop analysis of my data’.
5. Legal basis for using your information
In some cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a contract with you (for example, because you are receiving learning or therapeutic services from us).
However, there are other lawful reasons that allow us to process your personal information and one of those is called ‘legitimate interests’. This means that the reason that we are processing information is because there is a legitimate interest for The Empathy Coach to process your information to help us to achieve our vision of helping all of our clients and customers be the best that they can be.
Whenever we process your Personal Information under the ‘legitimate interest’ lawful basis we make sure that we take into account your rights and interests and will not process your personal information if we feel that there is an imbalance.
Some examples of where we have a legitimate interest to process your Personal information are where we contact you about our work via email, use your personal information for data analytics, conducting research to better understand what the needs of our customers are, improving our services or for our legal purposes (for example, dealing with complaints and claims).
We will only contact you about our work and how The Empathy Coach could support you by phone, email or text message, if you have agreed for us to contact you in this manner.
However, if you have provided us with your postal address we may send you information about our work and how you The Empathy Coach could support you by mail unless you have told us that you would prefer not to hear from us in that way.
You can update your choices or stop us sending you these communications at any time by contacting firstname.lastname@example.org or clicking the ‘unsubscribe’ link at the bottom of the relevant communication.
7. Sharing your Information
The personal information we collect about you will mainly be used by our staff and associates at The Empathy Coach so that they can support you.
We will never sell or share your personal information with organisations so that they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity.
The Empathy Coach may however share your information with trusted partners and suppliers who work with us on or commission our services, but processing of this information is always carried out under our instruction. We make sure that they store the data securely, delete it when they no longer need it and never use it for any other purposes. An example of where we may share your information is providing attendance records at learning or coaching sessions to the organisations that have commissioned or funded the activity.
We enter into contracts with these service providers that require them to comply with Data Protection Laws and ensure that they have appropriate controls in place to secure your information.
We may disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to comply to our own Public Liability and Professional Indemnity commitments.
8. Keeping your information safe
We take looking after your information very seriously. We’ve implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.
Unfortunately the transmission of information using the internet is not completely secure. Although we do our best to protect your personal information sent to us this way, we cannot guarantee the security of data transmitted to our site.
Our websites may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites. Please be aware that Web sites that have links on our site may collect personally identifiable information about you. This privacy statement does not cover the information practices of those websites.
Any debit or credit card details which we receive on our website or Eventbrite page are passed securely to PayPal, our payment processing partner, according to the Payment Card Industry Security Standards.
9. How long we hold your information for
We only keep it as long as is reasonable and necessary for the relevant activity, which may be to fulfil statutory obligations (for example, password-protected client notes that may be relevant to a child protection investigation).
In order to ensure that we do not mis-sell services to you, we do keep records of services you have previously commissioned from us or attended with us, indefinitely. This enables us to ensure we can always provide you with relevant products and services, and also enhance the follow-up offerings we provide to you (such as additional tools and resources that are relevant to the learning or coaching services you have received). If you do not wish for us to keep records of the services we have provided to you, nor provide you with additional free content or make you aware of other relevant products, free or chargeable, please contact us at email@example.com.
10. Your rights
You have various rights in respect of the personal information we hold about you – these are set out in more detail below. If you wish to exercise any of these rights or make a complaint, you can do so by contacting our Head Office team at The Empathy Coach by email at firstname.lastname@example.org.
Access to your personal information:You have the right to request access to a copy of the personal information that we hold about you, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge. Please make all requests for access in writing and provide us with evidence of your identity.
Right to object: You can object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. Please contact us as noted above, providing details of your objection.
Consent: If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time.
Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
No automated-decision making: Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law. You also have certain rights to challenge decisions made about you. We do not currently carry out any automated decision-making.
Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.
‘Cookie‘ is a name for a small file, usually of letters and numbers, which is downloaded onto your device, like your computer, mobile phone or tablet when you visit a website.
They let websites recognise your device, so that the sites can work more effectively, and also gather information about how you use the site. A cookie, by itself, can’t be used to identify you.
The cookies we use
We use the categorisation set out by the International Chamber of Commerce in their UK Cookie Guide.
We use all four categories of cookies:
Strictly necessary cookies are essential for you to move around our website and to use its features, like our shopping basket and your account.
Performance cookies collect anonymous information about how you use our site, like which pages are visited most.
Functionality cookies collect anonymous information that remember choices you make to improve your experience, like your text size or location. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
Targeting or advertising cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. As such if you visit the Mind website you may then be more likely to see adverts about Mind’s work on other websites as your browsing suggests that this is an area of interest.
No cookies, please
You can opt out of all our cookies (except the strictly necessary ones). Find out how to control and delete cookies in your browser.
But, if you choose to refuse all cookies, our website may not function for you as we would like it to.
Your communications with our teams (including by telephone or email) may be monitored and/or recorded for training, quality control and compliance purposes to ensure that we continuously improve our customer service standards.
To find out more about this policy and how we look after your personal information, contact our Head Office team at The Empathy Coach by email at email@example.com .