Privacy Policy

This policy (“Privacy Policy”) sets out the basis on which any personal data is collected from you or

that you provide, who we may share that data with and how we keep it secure. This document does

not provide exhaustive details. We are happy to answer any queries you may have on how we hold

and use your data. Any requests should be sent to the Data Controller (Glee Coaching Ltd) at

barbra@gleecoaching.com.

It is important that the information held about you is accurate and up to date. Please let Barbra

Carlisle know if your personal information changes by e-mailing her at barbra@gleecoaching.com.

We keep our Privacy Policy under regular review. This Privacy Policy was last reviewed in August

2023.

What we do

Glee Coaching Ltd provides learning and development services including coaching and leadership

development programmes to individuals and businesses. We do this online and face to face.

How we obtain your personal data

Personal data means any information capable of identifying an individual. It does not include

anonymised data.

We obtain data about you in the following ways:

● By signing a terms of business form

● During a coaching session

● Through e-mail, over the telephone, via Zoom or other virtual meeting platforms or by

post

● By taking credit card and payment online

This may include the following information:

● Contact details such as address, e-mail address, telephone number

● Bank details

● Communications data i.e. your preferences in receiving marketing communications e.g.

newsletter mailing

● Details of contact we have had with you (e.g. follow up information or referrals).

How will we use your personal data?

We will use your personal data in order to provide you with our services to you. This means that the

legal basis for our holding your data is for legitimate interest.

We act as a data controller for use of your personal data to provide learning and development

services. We act as data controller and processor, in regards to the processing of credit card and

online payments.

We undertake at all times to protect your personal data, in a manner which is consistent with the

requirements of the UK General Data Protection Regulations (GDPR) concerning data protection. We

also take reasonable security protection measures in order to protect your personal data storage.

We may use your personal data when there is an overriding public interest in using the information

e.g. in order to safeguard an individual, or prevent a serious crime. Also, where there is a legal

obligation such as a formal court order.

Consent for the use of your personal data will never be assumed. We may use your data for

marketing purposes, such as newsletters but this would be subject to you giving your express

consent.

Your personal data will only be used when explicitly given for the purposes for which it is collected,

unless reasonably considered that it is needed to be used for another purpose and that purpose is

compatible with the original purpose. If we believe that your life is in danger, then we may pass on

your information onto an appropriate authority using the legal basis of vital interests.

Children’s Privacy

We do not knowingly process data of EU residents under the age of 16 without parental consent. If

we become aware that we have collected data from an individual under the age of 16 without

parental consent, we will take steps to delete it as soon as possible.

Sharing of your information

We will only disclose your information with third parties with your express consent with the

exception of the following categories of third parties:

● Any legal or crime prevention agencies and/or to satisfy any regulatory request if we have

a duty to do so or if the law allows us to do so.



The information you share during any learning intervention such as one to one coaching is

anonymised and kept only for the purpose of supporting the learning and development of the coach,

for example during their coach supervision session. All data is held in accordance with the ethical

standards set out by the European Mentoring and Coaching Council and the Association for

Coaching. We do not store credit card details, nor do we sell, rent or share customer details with any third

party for commercial reasons.

What safeguards are in place to ensure that data that identifies you is secure?

We only use information that may identify you in accordance with GDPR. This allows us to process

personal data only if there is a legitimate basis for doing so and that any processing must be fair and

lawful. We ensure that the information we hold is kept in secure locations, restrict access to

information to authorised personal only, protect personal and confidential information held on

laptops with encryption (which masks data so that unauthorised users cannot see or make sense of

it). Barbra Carlisle is registered with the Information Commissioner’s Office (ICO) as a data controller.

What are your rights?

Every person has the right to access, amend, delete or have a copy of data held that can identify you,

with some exceptions. You do not need to give a reason to see your data. If you want to access your

data, you must make a subject access request in writing to barbra@gleecoaching.com. Under special

circumstances some information may be withheld. We shall respond within one month from the

point of receiving the request and all necessary information from you. Our response will include the

details of the personal data we hold on you including:

● Sources from which we required the information

● The purposes of processing the information.

You have the right, subject to exemptions, to:

● Have your information deleted

● Have your information corrected or updated where it is no longer accurate

● Ask us to stop processing information about you where we are not required to by law

● Receive a copy of your personal data, which you have provided to us in a machine-

readable format and have the right to transmit that to another data controller, without hindrance from us

●Object at any time to the processing of personal data concerning you.

We do not carry out automated decision making based on your personal data.

If you would like to invoke any of the above rights then please write to the Data Controller at

barbra@gleecoaching.com.

In the case of a breach of data, we will notify you and any applicable regulator of a breach if we are

legally required to.

Complaints

If you have any complaints regarding the use of your personal data, then please contact us in writing

to the Data Controller via e-mail barbra@gleecoaching.com and we will respond to you.

If your complaint has not been resolved to your satisfaction, you may wish to make a formal

complaint to the Information Commissioner’s Office (ICO), you can contact them on 0303 123 1113.

How long do we hold your data for?

Your personal data is retained for as long as necessary to fulfil the purposes it was collected for,

including the purposes of satisfying any legal, accounting or reporting requirements.

By law, basic information (including Contact, Identity, Financial and Transaction Data) needs to be

kept for tax purposes for six years after you cease to be a client.