Hatched Coaching Ltd GDPR Customer Privacy and Retention Policy

This privacy notice tells you what to expect us to do with your personal information.

Contact details

Post - 2&3 Westfield House, Millfield Lane, Nether Poppleton, York, YO26 6GA, GB

Email - hello@hatchedcoaching.com

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

• Names and contact details

• Occupation

• Third party information (such as family members or other relevant parties)

• Payment details (including card or bank information for transfers and direct debits)

• Transaction data (including details about payments to and from you and details of products and services you have purchased)

• Usage data (including information about how you interact with and use our website, products and services)

• Health information (such as medical records or health conditions)

• Information relating to compliments or complaints

• Video recordings

• Account access information

We collect or use the following personal information for the operation of client or customer accounts:

• Names and contact details

• Purchase or service history

• Account information, including registration details

• Marketing preferences

We collect or use the following personal information for information updates or marketing purposes:

• Names and contact details

• Profile information

• Marketing preferences

We collect or use the following personal information to comply with legal requirements:

• Name

• Contact information

• Client account information

We collect or use the following personal information to protect client welfare:

• Names and contact information

• Client account information

We also collect or use the following information to protect client welfare:

• Health information

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.

• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.

• Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.

• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.

• Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.

• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information to comply with legal requirements:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information to protect client welfare are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Where we get personal information from

• Directly from you

How long we keep information

As part of the day-to-day running of our business, we collect and process personal data from a variety of sources. This personal information is collated in several different formats including emails, legal documents, operations records,. The personal data is stored in electronic form. Our business will ensure that the personal data that we hold is kept secure and that it is held for no longer than is necessary for the purposes for which it is being processed. In addition, we will retain the minimum amount of information to fulfill our statutory obligations and the provision of goods or/and services – as required by data protection legislation, including the General Data Protection Regulation (GDPR). 

This retention policy (along with its schedule), is a tool used to assist us in making decisions on whether a particular document should be retained or disposed of. In addition, it takes account of the context within which the personal data is being processed and our business practices.

Decisions around retention and disposal are to be taken in accordance with this policy. 

As and when the retention period for a specific document has expired, a review is always to be carried out prior to the disposal of the document. This does not have to be time-consuming or complex. If a decision is reached to dispose of a document, careful consideration is to be given to the method of disposal. 

Responsibility 

• Hatched Coaching Ltd Company Director/s is responsible for keeping this retention schedule up to date in order to reflect changing business needs, new legislation, changing perceptions of risk management and new priorities for our business.

• Hatched Coaching Ltd Company Director/s is responsible for determining (in accordance with this Policy) whether to retain or dispose of specific documents.

• Hatched Coaching Ltd Company Director/s may delegate the operational aspect of this function to Support Worker/s.

• Support Worker/s should inform Hatched Coaching Ltd Company Director/s if there is any doubt about the minimum retention periods or if the retention of a document is necessary for a potential claim. 

Disposal

Our business must ensure that personal data is securely disposed of when it is no longer needed. This will reduce the risk that it will become inaccurate, out of date or irrelevant. The methods of disposal are to be appropriate to the nature and sensitivity of the documents concerned and include: 

• Non-Confidential records: place in waste paper bin for disposal 

• Confidential records: shred documents 

• Deletion of Computer Records

• Transmission of records to an external body 

• Cloud storage

The table below contains the retention period that we have assigned to each type of record. This will be adhered to wherever possible, although it is recognised that there may be exceptional circumstances which require documents to be kept for either shorter or longer periods. 

Exceptional circumstances should be reported to Hatched Coaching Ltd Company Director/s without delay.

Document retention schedule