GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
We, Liz Margree Limited, 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, passport number, 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?
Liz Margree (Director of Liz Margree Limited) is the data processor. This means Liz Margree Limited is responsible for processing personal data on behalf of a data controller.
Liz Margree’s contact details are:
For all data matters contact Liz Margree using the contact details listed above.
- The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- To facilitate communication with clients when entering into and carrying out a contract
- To inform, but not limited to, coaching sessions, workshops and team meetings
- 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:
- Contact details (name, job title, work email address, work address, mobile phone number and work phone number)
- Psychometric reports
- Hand written notes on coaching sessions
We will either obtain contact details directly from a data subject or from a line manager, head of department or another person managing the contract within the organisation (see point 8).
- 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:
|☐ Consent of the data subject
(See 3i & 3ii)
|√ Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract (See 3i & 3ii)||· Coaching sessions
· Team meetings
· Keeping records for 18 months after a completed contract in case a client returns for further coaching (or relevant work)
· Consent will be obtained as part of our contractual agreement with a client (the data controller)
|√ Processing necessary for compliance with a legal obligation||· Accounts (including records of invoices and purchase orders), will be kept for 7 years for tax purposes|
|☐ Processing necessary to protect the vital interests of a data subject or another person||N/A|
|☐ Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller||N/A|
|☐ 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||N/A|
- special categories of personal data (article 9 of GDPR)
WE DO NOT PROCESS SPECIAL CATEGORIES OF DATA
- Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared with Liz Margree and Laura Yeldham (administrator).
Consent will be obtained, as part of a contractual agreement, if data is to be shared with other parties (for example in the case of sub-processing).
Psychometric reports will only be shared with Liz Margree.
Liz Margree employs the services of a bookkeeper and an accountant. Liz Margree will only share data that is essential to the management of her accounts. This will usually only reference client’s names and work address. Please see point 5 and point 7.
- How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary, see list below for the period of time and reason for retaining personal data.
|Purpose||Period of time|
|· Contact information to facilitate communication with clients||This will be kept for as long as the working relationship exists|
|· Psychometric reports to inform coaching sessions and team meetings||These are not kept and destroyed once they have been sent to the client|
|· Notes to inform coaching sessions||Hand written notes are kept for 18 months after the completion of a contract in case a client returns for further coaching|
|· Records of accounts for tax purposes (including invoices and purchase orders with reference to client names and work addresses)||Accounts will be kept for 7 years as required for tax purposes|
- Providing us with your personal data
We require your personal data as it is necessary to enter and carry out a contract.
Where a third party (as referenced in point 4) has shared personal details of an employee with Liz Margree (in order to facilitate a contract), they will ensure that they have received consent to do so and will inform the employee of their rights listed below in point 9.
- 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, where consent was the lawful basis for processing the data
- 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).
- All requests have a month in which to be carried out.
- Transfer of Data Abroad
we do not transfer personal data AT ALL
- Automated Decision Making
We use Insights©, Myers Briggs Type Indicator and Hogan psychometric tools to inform coaching sessions and team meetings. Individual clients complete the questionnaire independently and voluntarily and the report is then created by Liz Margree, Director of Liz Margree Limited, only, and then only shared with the individual who completed the questionnaire, in complete confidence. Psychometric reports are destroyed once they have been sent to the client (see Section 7).
Insights, Myers Briggs Foundation and Hogan may store your data on their secure servers unless you request the deletion of your records, please refer to their Privacy Statements for further guidance.
- 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 Liz Margree on firstname.lastname@example.org.
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.