Privacy Policy 

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1. Introduction 

Coaching for Unpaid Carers CIC (CfUC) is committed to working ethically, including taking your privacy seriously. Our aim is that each person we communicate with feels comfortable to share their data with us and is confident that they have given their explicit permission for the ways in which we use and process that data. 

This policy explains how we ensure that we abide by legal and good practice requirements for data protection, confidentiality and processing and storage of data and personal information collected from people who contact us or work with us (e.g. people who visit our website, send us emails, request or receive our services, attend our events, or supply us with services). 

 

2. Policy changes 

We will review and may change this policy from time-to-time and updates will be uploaded onto our website. Any questions regarding this Policy and our privacy practices should be sent by email to:  hello@coachingforunpaidcarers.org.uk.

This Policy was last updated in April 2020.

 

​3. Data protection

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3.1 Date protection principles

In the course of our work, it will be necessary for us to record personal information about our clients. The use of such information requires compliance with the Data Protection Act 1998 and General Data Protection Regulations (GDPR) 2018. The Data Protection Act/GDPR applies to personal information about an individual - “the data subject” - whether it is stored on computer files or in manual records.

Important Note: Personal data covers both facts and opinions about an individual. It also includes information regarding the intent of Coaching for Unpaid Carers CIC towards the individual. The definition of “processing” incorporates “obtaining”, “holding” and “disclosing”.

 

The Act sets out 8 fundamental principles which must always be observed. The data must be:

1. fairly and lawfully processed

2. processed for limited purposes

3. adequate, relevant and not excessive

4. accurate

5. not kept for longer than is necessary

6. processed in accordance with the rights of data subjects

7. secure

8. not transferred to countries without adequate protection.

Please see Section 5 for how we apply these principles in practice.

 

3.2 Compliance with the Act

Compliance with the Data Protection Act/GDPR requires that we take particular care regarding personal and sensitive information about our clients.  To facilitate compliance, anyone who works for Coaching for Unpaid Carers CIC, in whatever capacity (including directors, board members, paid staff, volunteers, associates or contractors) must sign an agreement to make sure they understand and abide by all CfUC processes and policies. 

 

3.3 Registration with the Information Commissioner’s Office (ICO)

Coaching for Unpaid Carers CIC is registered with the Office of the Information Commissioner (reference number: ZA736190).  This registration sets out the purposes for which personal information is collected and processed.

More information on the Act, data protection compliance, as well as the details and full text of the registration for Coaching for Unpaid Carers CIC is available from The Information Commissioners Office via the ICO web site www.ico.org.uk, or by phone 0303 123 1113.

 

3.4 Know your rights, and how to help us get it right

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to: 

• Request access to your personal data (known as “Data Subject Access Requests”)

• Request correction of your personal data 

• Request erasure of your personal data 

• Object to processing of your personal data 

• Request restriction of processing your personal data 

• Request transfer of your personal data 

• Right to withdraw consent. 

You can see more about these rights at 

www.ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

If you wish to exercise any of the rights set out above, please contact our nominated Data Protection Officer, Katharine Collins, who can be contacted in writing either by post, at Room 135, 16 Upper Woburn Place, London WC1H 0AF, or by email at hello@coachingforunpaidcarers.org.uk.

 

Please Note

We will charge you a small fee (of £15 to cover our administrative costs) to access your personal data (or to exercise any of the other rights). We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

We try to respond to all legitimate requests within three weeks. Occasionally it may take us longer if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated. 

If you have spotted a problem with how we are handling your data, please contact us and we will do our best to resolve the issue with you. If we are unable to resolve the issue to your satisfaction you can make a formal complaint to the Information Commissioners Office (ICO) https://ico.org.uk/concerns.

 

4. Confidentiality

Confidentiality, particularly how we deal with disclosures made to us by clients as part of our work together, is an important issue for Coaching for Unpaid Carers CIC, and is essential for our clients to trust us and have confidence in the work we do.

 

4.1 Coaching for Unpaid Carers CIC principles of confidentiality

Anyone who works for Coaching for Unpaid Carers CIC, in whatever capacity (directors, board members, paid staff, volunteers, associates or contractors) must

• sign an agreement to make sure they understand and abide by all CfUC processes and policies, including the confidentiality policy

• not discuss the work of Coaching for Unpaid Carers CIC (verbally or in writing) with people outside the company, such that a client (or their family) may be identified (except with their express permission).

• adhere to the Coaching for Unpaid Carers CIC data protection policy and any guidelines we provide.

 

4.2 What do we mean by Confidentiality?

Confidentiality means that no information about a client is given to a third party without the client’s express consent. Permission to disclose must not be assumed, but informed consent must be sought and given expressly for the particular purpose discussed.

The exception will be if a safeguarding issue arises, when the client will be made aware that their information will be shared with others, but only on a need to know basis.

If in the course of our work, we are told something that suggests that a child or a vulnerable adult[1] may be at risk of abuse or being harmed, we have a legal duty to pass that information on to the relevant safeguarding team at the local authority.

Please see our safeguarding policy for more details.

 

5. How we process your data

 

5.1  Who is collecting it? 

‘We’, ‘us’ and ‘our’ includes Coaching for Unpaid Carers CIC and any staff or volunteers who are working for us.  In order to provide the service you have requested from us, we may also forward your details with your consent to members of the Coaching for Unpaid Carers Network. All these people are required to abide by Coaching for Unpaid Carers CIC policies as part of their contract with us.    

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5.2 What information is being collected and how?

 

Personal data

• Name and contact information that you supply (including by completing the form or clicking on the email link on our Contact-us page on our website) e.g. address, postcode, email address, telephone number (landline and mobile), linked-in/Skype address, social media identifiers.

• Other personal data which we need to collect from coaching clients (such as gender, occupation, age, date of birth, family details, ethnic group, state of health, opinions or beliefs, sexuality).

• Notes from coaching sessions, workshops, exercises, surveys or questionnaires, evaluation activity that we gather during our work together (which may include your personal opinions, views and experiences) as well as from emails, conversations, texts, Linked-in/Skype or similar contacts, and collaborative work tools such as Drop Box/Slack. We will always ask your permission to do this when we start working together.  

• Where relevant, we may collect business contact information, such as, organisation/company name, job title, and department. 

• Copies of any invoice, receipt or other financial document, which may include bank details, that are sent to us by clients or contractors.  

 

Accessing and updating your information

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The accuracy of your information is important to us.

If you change email address, or any of the other information we hold is inaccurate or out of date, please email us at: hello@coachingforunpaidcarers.org.uk. You are entitled to access the personal information we hold about you (which is known as a subject access request) and you have the right to update any incorrect information (please see Data Protection section above).

You also have the right to withdraw consent you gave for participation in our evaluation at any time.

 

Cookies

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Cookies provide information regarding the computer used by a visitor to our website. We may use cookies where appropriate to gather information about your computer to assist us in improving our website. Where used, these cookies are downloaded to your computer and stored on the computer's hard drive. Such information will not identify you personally. It is statistical data which does not identify any personal details whatsoever. 

You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer. 

 

5.3 Why is it being collected and how will it be used?

We will only use your personal information to provide the services you have requested from us and, occasionally, with your consent: 

• to seek your views or comments on the services we provide

• to request references or testimonials required by potential clients

• to connect you with other people within our network for the purposes of delivering the services you have requested from us

• to make you aware of developments at Coaching for Unpaid Carers CIC that we feel are relevant to you

• Combined with the responses/views/opinions/experiences of others who we work with for the purpose of evaluation, reports, articles or presentations about our work. Any personal identifiers will be changed or deleted so that individuals will not be able to be identified personally, except with their consent

 

5.4 Who it will be shared with?

Your personal information will be shared with members of Coaching for Unpaid Carers CIC who are working with you for the purposes of the work we are contracted to do with you.  

This may include other companies and individuals who are carrying out work on our behalf, who will have access to the personal information needed to deliver the service but will not use it for other purposes. They must also process the personal information as set out in this Privacy Policy and as permitted by the UK’s Data Protection Act/laws. 

Anyone who works for Coaching for Unpaid Carers CIC, in whatever capacity (including directors, board members, paid staff, volunteers, associates or contractors) must sign an agreement to make sure they understand and abide by all CfUC processes and policies. 

If you are a supplier or contractor who has sent us an invoice, receipt or other financial document, we may provide those documents to our accountants for accounts and tax purposes. 

For personal information unrelated to legal or tax purposes, we will only pass on your contact details to others with your written (email) consent. 

Coaching for Unpaid Carers CIC never sells personal data. 

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5.5 Third party links

Our website or platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 

In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.

 

5.6 International data transfers

Other countries have different data processing laws and procedures and there are international protocols in place to protect data that is transferred between certain countries. Given the UK’s departure from the EU, the detail of how these protocols will work is still being worked out and we will update our policy once we know how this will affect us and our work.

We do not anticipate that your data will be transferred outside the UK, however, it is possible that this might happen if the companies that own the applications that we use e.g. for data processing or other internet-based applications are based in other countries. If you use our services while you are outside the UK, your information may be transferred outside the UK in order to provide you with those services.

 

5.7 How your information is stored securely

We have put in place appropriate technical, administrative and physical security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Should we suspect a personal data breach, we will notify you and any applicable regulator of a breach where we are legally required to do so, investigate and take appropriate action. 

Coaching for Unpaid Carers CIC currently holds personal data in a variety of forms.

• Electronically, such as emails spreadsheets, databases and other documents saved on computer equipment and back-up systems, on mobile telephones and other mobile devices and servers. Personal data will be stored on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contracts we hold.

• We also hold paper records such as notes from coaching sessions, hard copies of forms that have been completed by clients, supervision notes. These notes are destroyed by shredding at the end of the coaching contract and/or once any evaluation or agreed follow-up activity has been completed. 

We review, monitor and evaluate our privacy practices and protection systems on a regular basis. Our current security measures include:

• Taking steps to control physical access security – ensuring that paper records are kept in locked desks or filing cabinets and that all computer equipment is protected with a password and an internet firewall and anti-virus security system.  

• Putting in place controls on access to sensitive or personal information – this includes procedures and software controls for authorising and authenticating data users and restricting access to files (such as password protecting documents) and techniques for protecting data (such as encryption) for sending documents that contain sensitive or personal information.

• Anonymising client-related records stored using a coding system

• Ensuring that email communications do not contain any sensitive personal information and abide by GDPR guidance.

• Requiring anyone who works for Coaching for Unpaid Carers CIC, in whatever capacity (including directors, board members, paid staff, volunteers, associates or contractors) to sign an agreement to make sure they understand and abide by all CfUC processes and policies. 

 

6. Finally

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How you can opt-out/unsubscribe from Coaching for Unpaid Carers communications 

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You can opt out of/unsubscribe from receiving communication from us at any time by contacting us directly or via our website  www.coachingforunpaidcarers.org.uk

 

Queries

If you have any queries concerning this policy, our website or our work. or would like to make a subject access request, please contact us.

If you have concerns regarding how your personal information has been processed by us, you can make a complaint to the Information Commissioners Office (ICO): Website www.ico.org.uk; Telephone: 0303 123 1113.

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