GDPR: Data privacy notice
*Please note that we are waiting for final guidance on the GDPR from the ICO. Regularly check back to make sure that you are using the most up-to-date version of this document.
Greenfields Consulting Limited (“We”) are committed to protecting and respecting your privacy.
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.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
- Who are we?
Michelle Lucas of Greenfields Consulting Limited is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: firstname.lastname@example.org or 07717 122950.
- The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- Communications relating to delivery of one or more of our client facing services
- Promotional communications advising the data subject of Greenfields Consulting Limited related information and/or services which we believe may be of interest to you
- The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Personal data (name, home address; private and work email addresses; phone numbers; company related information e.g. Registered Address, Registered Company Number; VAT number)
- Special categories of data – NONE
We have obtained your personal data from you directly during the course of doing business with you either on a private or public (e.g. open workshop or conference) basis.
- What is our legal basis for processing your personal data?
Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
Typically Executive Coaching; Coaching Supervision; Coach Development Programmes; or bespoke consultancy arrangements
Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject
Information or promotional material relating to Greenfields Consulting Limited products and services.
E.g. quarterly newsletters; Christmas Cards; ad hoc e-mails advising of CPD events
More information on lawful processing can be found on the ICO website.
- Sharing your personal data
Your personal data will be treated as strictly confidential and will be shared only with personnel directly contracted with Greenfields Consulting Limited and who have an “@greenfields.co.uk” e-mail address.
- How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes
- You are a client receiving one of Greenfields Consulting Limited’s services
- You are a dormant client who has agreed to keep an active connection with Michelle Lucas
We will review our distribution list on an annual basis and identify for which Data Subjects our contact has lapsed. We will then seek explicit permission to either keep or remove information relating to them.
- Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will mean we are unable to communicate with you about ongoing or potential services.
- Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time.
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
- Transfer of Data Abroad
- Automated Decision Making
We do not use any form of automated decision making in our business.
- Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
- How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact Michelle Lucas (see 2 above).
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
- Note: This document was developed using a template gained as a member of the FSB and provided by LHS Solicitors owns the copyright in this document