This policy deals with how themummycoach.co.uk handles “Personal Data’ as defined in the GDPR (General Data Protection Regulation). It will inform you as to how I look after your personal data and tell you about your privacy rights and how the law protects you.
Who I am
I am Elizabeth Davies, the owner of The Mummy Coach. I respect your privacy and am committed to protecting your personal data.
Purpose of this privacy notice
This privacy notice applies to the personal data of my website users and other people who may contact me either:
i) through use of this website, including any data provided through this website when you complete an online screening form; or
ii) by electronic means or otherwise to request information from me
and aims to give you information on how I collect and processes your personal data.
I am the data controller and am responsible for your personal data. I have responsibility for data protection compliance. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the me using the details set out below.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance.
Your duty to inform me of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website 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.
The data I collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
I may collect, use, store and transfer different kinds of personal data about you which I have grouped together follows:
Identity Data includes first name, last name, username or similar identifier and title.
Contact Data includes address, email address and telephone numbers.
Special Category Data, namely health details.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password and preferences.
Usage Data includes information about how you use our website.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
I also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
When you visit my website I use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various pages of my site or what browser is being used. This information is processed in a way which does not identify anyone i.e. does not collect personal data. I do not make any attempt to find out the identities of those visiting my website.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: make an enquiry via my website; complete my online screening form; subscribe to my newsletter or request marketing to be sent to you; give me feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Technical Data from analytics providers, such as Google, based outside the EU.
Special Category Data from the software which I use for my screening forms, based outside the EU
How I use your personal data
I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:
Where I need to perform the contract I am about to enter into or have entered into with you.
Where you have consented to the processing of your personal data
Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Purposes for which I will use your personal data
I have set out below a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.
Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I are using your data. Please contact me if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the list below.
1. To register you as a new customer, including requiring you to complete a screening form
Type of data: (a) identity, (b) contact, (c) special category - health
Lawful basis: (a) performance of a contract with you, (b) consent
Condition for Special Category Data: explicit consent
Type of data: (a) identity, (b) contact, (c) profile, (d) marketing and communications
Lawful basis: (a) performance of a contract with you, (b) necessary to comply with a legal obligation, (c) necessary for our legitimate interests (to keep my records updated and to study how customers use my products/services)
3. To administer and protect my business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) identity, (b) contact, (c) technical
Lawful basis: (a) necessary for my legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), (b) necessary to comply with a legal obligation
You can ask me to stop sending you marketing messages at any time by contacting me.
Change of purpose
I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact me.
If I need to use your personal data for an unrelated purpose, I will notify you and will explain the legal basis which allows me to do so.
Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
· External Third Parties as set out in the Glossary.
I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
I do not have any group entities outside of the EEA, as such we do not transfer your personal data outside the European Economic Area (EEA).
I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your personal data to third parties who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where I am legally required to do so.
How long will you use my personal data for?
I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.
Your legal rights
Under certain circumstances, you have rights under data protection laws to:
If you wish to exercise any of the rights set out above, please contact me.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.
What I may need from you
I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up my response.
Time limit to respond
I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of my business in conducting and managing my business to enable me to give you the best service and the best and most secure experience. I make sure I consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for my legitimate interests. I do not use your personal data for activities where my interests are overridden by the impact on you (unless I have your consent or am otherwise required or permitted to by law). You can obtain further information about how I assess my legitimate interests against any potential impact on you in respect of specific activities by contacting me.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that I am subject to.
Internal Third Parties
External Third Parties
· Health care and other professionals involved in your care
· Service providers acting as processors who provide IT and system administration services.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.