Data Protection Policy For Coaches
This notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you during the time you coach with us and, where appropriate, after you no longer coach with us. We are required to notify you of this information under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘Privacy Notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.
Who collects the information?
DotCoach CIC trading as Know You More (the ‘Organisation’) is a ‘data controller’ and gathers and uses certain information about you. Where the Organisation is also a ‘data processor’, we will process information received from third parties about you.
Data Protection principles
We will comply with the data protection principles when gathering and using personal information, as set out in our Data Protection Policy.
About the information we collect and hold
The table set out on the following pages summarises the information we collect and hold, how and why we do so, how we use it, and with whom it may be shared.
We may also need to share some of the categories of personal information set out below with other parties, such as external contractors, clients and our professional advisers. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal information with our regulators and/or our funders as is necessary or required to comply with the law.
We seek to ensure that our information collection and processing is always proportionate – that is, we only collect and process what we need to, and we only store it for as long as we need to. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.
Where information may be held
Information may be held at our offices and by third-party agencies, service providers, representatives and agents. We have security measures in place to seek to ensure that there is appropriate security for information we hold.
How long we keep your information
We keep your information during and after the time you coach with us, and for no longer than is necessary for the purposes for which the personal information is processed. Further details on this can be found in our Retention Policy.
Your rights to correct and access your information and to ask for it to be erased
Please contact Chirag Mehta who can be contacted on email@example.com if (in accordance with applicable law) you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask Chirag Mehta for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances. Chirag Mehta will provide you with further information about the right to be forgotten, if you ask for it.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Changes to what we do
We regularly review and, where necessary, update our privacy information, policies, procedures and privacy notices. If we plan to use your personal information for a new purpose we will update our documentation and privacy notice, and communicate the changes to you before starting to use the information in a new way.
How to complain
We hope that Chirag Mehta can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.
Schedule relating to the information we collect and hold
|The information we collect||How we collect the information||Why we collect the information||How we use and may share the information|
|Your name, age, contact details (i.e. address, home and mobile phone numbers, e-mail address) and emergency contacts (i.e. name, relationship and home and mobile phone numbers)||From you||• To enter into/perform the coaching arrangement with you
• Legitimate interest: to maintain coach records and good coaching practice
|• To enter into/perform the coaching arrangement with you|
|Criminal records background checks (Basic, Standard or Enhanced Disclosure Checks and/or PVG Scheme Membership checks), including the results of Disclosure Services (Volunteer Scotland), Disclosure Scotland and Disclosure and Barring Service (DBS) checks||From you and Disclosure Services (Volunteer Scotland)/Disclosure Scotland and/or the DBS||• To perform the volunteering agreement
• To comply with our legal obligations
• For reasons of substantial public interest [ (preventing or detecting unlawful acts, [ suspicion of terrorist financing or money laundering in the regulated sector] and protecting the public against dishonesty)]
|• To carry out statutory checks
• Information shared with Disclosure Services (Volunteer Scotland)/Disclosure Scotland and/or DBS and other regulatory authorities as required
• For further information, see * below
|Information on feedback raised by or involving you||From you, from other volunteers, service users, clients, employees of the Organisation, from other third parties and from consultants/professional advisors we may engage in relation to the complaints procedure||• To perform the coaching agreement
• To comply with our legal obligations
• Legitimate interests: to maintain coaching records and to comply with legal, regulatory and corporate governance obligations and good coaching practice
|• For coaching administration, to follow our coaching policies and to deal with complaints
• Information shared with relevant managers, HR personnel, relevant third parties and with consultants/professional advisors we may engage from time to time
|Details of reviews of your coaching activities and training activities||From you, from other coaches and employees||• To comply with our legal obligations
• Legitimate interests: to maintain coach records and to comply with legal, regulatory and corporate governance obligations and good coaching practice, to ensure safe working practices
|• For coaching administration, to follow our coaching policies including policies on induction and training and development and to deal with disciplinary matters or complaints
• Information shared with relevant managers, HR personnel and with consultants/professional advisors we may engage from time to time
|Details of your time and attendance records||From you and your coachee for any sessions held||• To perform the coaching arrangement
• Legitimate interest: to manage coaching access to our systems and facilities and to record coaching absences
|• For administrative purposes and to follow our coaching policies and monitor coaching attendance|
|Information about your use of our IT, communication and other systems||Automated monitoring of our websites and other technical systems, such as our platform||• Legitimate interests:
• to monitor and manage coach access to our systems and facilities
• to protect our networks, and personal data of employees, coach and customers/clients, against unauthorised access or data leakage
• to ensure our business policies, such as those concerning security and internet use, are adhered to
• for operational reasons, such as maintaining coach records, recording transactions, training and quality control
• to ensure that commercially sensitive information is kept confidential
• [for security vetting and investigating complaints and allegations of criminal offences]
• [for statistical analysis]
• to prevent unauthorised access and modifications to our systems
• as part of investigations by regulatory bodies, or in connection with legal proceedings or requests
|• To protect and carry out our legitimate interests (see adjacent column)
• Information shared with relevant managers, HR personnel [and with consultants/professional advisors we may engage from time to time
• For further information, see ** below
* Further details on how we handle sensitive personal information and information relating to any unspent criminal convictions and offenses are set out in [set out details of the policy on processing ‘special categories of data’ (i.e. sensitive personal data) and, where relevant, the policy on criminal records information]
** Further information on the monitoring we undertake in the Organisation and how we do this is available in our [insert details of the relevant policy that deals with monitoring undertaken by the employer] available from [set out details of how volunteer can access the policy]