- Information you provide to us
This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purpose of Data Protection legislation, the data controller is Adaptaa Ltd (registered company number: 10375190), with registered office at 5 Charles Talbot Mews, London, SE22 8AZ (“we”, “us”, and “our” and other similar terms).
- Information we may collect and request from you
We may collect and process the following data about you:
- Information you give us or that we collect from you. You may give us personal information by corresponding, emailing, filling in forms, uploading content to our Website, by phone and face to face and in notes taken during coaching and workshop activities. The information you give us may include your name, home address, personal e-mail address, home phone number, personal description, photograph, gender, job title, job description and area of responsibility.
- Technical information including the Internet protocol (IP) address. This is used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Information about your visit to our website. This includes the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our service number/s.
- Information we receive from other sources. We may receive information about you from your employer and your colleague/s.
- Purpose and legal basis for processing
- Information that you give us or that we collect from you
The data that you provide is essential for us to administrate our coaching or workshop services and processing, use and retention of the data is lawful and relevant to the matter being dealt with by us.
- Information we receive from other sources
We collect data about you from your employer and colleagues for the performance of a contract you are party to (for example, a 360 feedback interview) or prior to you entering into a contract (for example, a conversation with HR or your line manager). The collection of data during these processes is lawful, relevant and limited to the matter/s being dealt with by us.
- How will we use your personal data?
The information you supply, or that we collect, about you may be used by us for:
- Contacting you in relation to coaching work and keeping you informed during assignments;
- Informing employers or other commissioning parties subject to prior approval and consent;
- Scheduling meetings with you;
- Administration and accountancy by us;
- Keeping you informed of developments and services we offer that we believe may be relevant to you;
- Sharing news with you concerning events or workshops we are organising;
- Performing analytics such as analysing psychometric data and graphs for the purposes of delivering coaching, consultancy assignments and / or workshop services to you.
- Who else will have access to your data?
We may share your personal information with third parties such as:
- other coaches and business partners involved in delivering services to you;
- providers who administer psychometric testing;
- parties involved in preparations for events;
- professional accreditation institutions that provide qualitative assessment and audit of our products and services;
- disclosures required by law or regulation.
Our website may contain links third-party websites. You should review the privacy and confidentiality policy of any third party website that you may visit in order to understand how third parties may collect, store and use your personal information.
- Will we transfer data overseas?
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the provision of data administration on your behalf, the processing of your details and the provision of support services.
- Data Retention Period
The data that we collect from you will be processed for the purpose for which it was collected and it will be retained during the processing period in order to provide the services.
In addition, we will archive data for a period of 10 years after closure of the processing of the data to prevent destruction of critical information that you may want to access in the future.
You can exercise your rights contained in section 8 at any time concerning your data.
- Your rights
You have certain rights with regard to your personal data processed by us and these are described in this section.
- You have a right to access your personal data that we hold on our database about you and this can be done by making a Subject Access Request to our Data Protection Officer whose contact details are in section 10.
- If you believe the data we hold about you is incorrect, you have a right to have this corrected.
- With exceptions, you have the right to request the deletion of personal data we hold about you. We will consider every request for erasure on its merits.
- You have a right to request us to restrict the processing of your personal data for the period it takes us to rectify any inaccurate data about you. This right can also be used to prevent us from deleting your data at the end of the retention period in the unlikely event that you need it to establish, exercise or defend a legal claim.
- Data Protection Officer
- Complaints Process
If you have any complaints about how we handle your personal data, please contact the Data Protection Officer whose details are in section 10 above and we will respond to you in 2 working days.
If, after we have given you our final response, you continue to be dissatisfied, you have a right to lodge a complaint with: -
Information Commissioner’s Office
Tel: 0303 123 1113 or 01625 545 745
The ICO currently recommends that you contact them within 3 months of your last contact with us.