DATA PRIVACY NOTICE – REVISED MARCH 2018
James Butler, sole trader, trading as James Butler Coaching
Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by legislation known as the General Data Protection Regulations (the GDPR).
Who are we?
I, James Butler, am the data controller (contact details below). This means I decide how your personal data is processed and for what purposes.
How do we process your personal data?
I endeavour to comply with my obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. I will not collect or process any data that I do not need in order to operate as a coach.
I will use your personal data for the following purposes:
|For visitors to our website:
|For enquirers, clients and former clients:||I process your personal data, including names, addresses and contact details and in some circumstances age and business information in order to legitimately administer my potential or actual coaching relationship with you.
I may also use your personal data for marketing purposes – to send occasional newsletters (probably monthly) and other occasional emails linking to my blog. From 1st March 2018 this will be purely on an informed consent basis.
|For suppliers:||I process your contact information in order to manage my commercial relationship with you and to meet financial reporting obligations.
|For those who pay online:||I process data from my suppliers Bank of Ireland (Post Office Money) and Paypal in order to fulfil orders and legitimately administer my accounts.|
What is the legal basis for processing your personal data?
With the exception of the marketing purposes above, I have considered that processing the data is in the legitimate interests of myself to properly and responsibly operate my coaching business.
From 1st March 2018, the processing of the data of hirers for marketing purposes will be in the basis of informed consent, through an opt-in email list.
How long will we keep the data?
|For visitors to our website:
|Our website stores cookies for 1 year.|
|For enquirers, clients and former clients:||Data related to enquiries/engagements will be held for up to seven years, as part of my financial records.
Data related to marketing will be held for two years after unsubscription.
|For suppliers:||Data related to suppliers/potential suppliers will be held for up to seven years, as part of my financial records.
|For those who pay online:||Data related to transactions will be held for up to seven years, as part of my financial records.
What are your rights?
If at any point you believe the information I process on you is incorrect you may request to see this information (this is called a Data Subject Access Request) and even have it corrected or deleted (subject to some legal restrictions). To make a Data Subject Access Request or to make a complaint about how I have handled your personal data, you can contact me as the Data Protection Officer and I will investigate the matter.
If you are not satisfied with my response or believe I am processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (www.ico.org.uk).
My Data Protection Officer is me (I am a sole trader, after all), James Butler and you can contact me at firstname.lastname@example.org.