This privacy policy applies to the website (“http://www.TWPC.co.uk/“) operated by The Wellbeing & Performance Ltd and its affiliates (“The Wellbeing & Performance company”, “TWPC”, “we”, “our” and “us”) and to the processing of personal information by The Wellbeing & Performance Company Ltd as contemplated in this privacy policy. Any reference to “you” or “your” means you, the user.
The Wellbeing & Performance Company Ltd respects your privacy and is committed to protecting the personal information you share with us. This statement describes how we collect and use your personal information that we may collect about you through the Site and from our communications with you.
PRIVACY NOTICE
The Wellbeing & Performance Company website and online services are designed to protect the privacy of all users. We ensure that the data you supply to us is processed fairly and lawfully. This Data Protection Policy governs our processing of all personal data provided to us, in all forms. By registering your details with us and using our website, you consent to us collecting and processing personal data supplied by you and disclosing this information to prospective employers and clients in connection with the recruitment process.
INTRODUCTION
This Privacy Notice provides you with clear information as to how we process your personal data. We are obliged to use your information in line with all applicable laws. We do so in a manner that is fair by using your information in a way that you would reasonably expect when providing our work-finding services or recruiting personnel for you, and being transparent so that you know how it will be used.
This Privacy Notice sets out the types of personal data that we collect about you, how and why we use it, how long we will keep it for, when why and who we will share it with, the legal basis for us using your personal data and your rights in relation to us storing and processing your personal data. It also explains how we may contact you and how you can contact us.
Part of the coaching process will involve sharing your personal data with our independent coaches & trainers (independent data controllers) who have potential opportunities that may be suitable for you. These third parties will have their own privacy policies and will also need to comply with all applicable laws – we encourage you to contact them directly if you have any concerns or questions about your data.
WHO WE ARE
The Wellbeing & Performance Group Ltd (1151777) is a performance training & coaching company.
We are registered as a data controller with the ICO in the United Kingdom for the purposes of the Data Protection legislation and General Data Protection Regulation (GDPR). Our registered office address is 30-34 North Street, Hailsham, East Sussex BN27 1DW. Our actual office is The Studio, The Johns Cross, Battle Road, Robertsbridge, East Sussex TN32 5JH and you can contact us at dataprotection@TWPC.co.uk if you have any queries relating to data protection.
LEGAL BASIS FOR PROCESSING YOUR DATA
For prospective coachees, contractors, referees, trainees and clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees.
We do not consider our legitimate interests to be overridden by your interests or fundamental rights and freedoms. We take into consideration the reasonable expectations of individuals who are actively applying for jobs or making their personal information publicly accessible on professional networking sites.
If you are undertaking coaching or training, then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. We will ask for your consent before undertaking such processing if we are required to do so.
For clients, we may also rely on our processing being necessary to perform a contract for you if one is in place, for example in contacting you.
WHAT INFORMATION WILL WE COLLECT ABOUT YOU?
We collect and process personal data only as far as is necessary to facilitate the coaching process and provide you with coaching or training practices. We need your personal data in order to work with you professionally and in your best interests taking all of your relevant information into account to enable the best outcome for you and/or your team and/or your company and therefore may be needed to assess you through the different stages of the coaching/training process.
The information we collect may include your name, email address, telephone number, doctor’s details, employment history and personal information given in strict confidence during a coaching session.
In general, we will not ask you about sensitive personal data but there may be times that it is necessary for information to be disclosed to us and for us to share that with potential clients. We will only share the information where you have provided your explicit consent.
WHERE DOES THE INFORMATION WE COLLECT ABOUT YOU COME FROM?
The data we collect about you is obtained from the following sources:
- Directly from you. This may be via our registration process for services, social media platforms, information requests and applications via our website or during the coaching/training process.
- An agent or third party acting on your behalf. This may be where you are consulting via a Limited Company.
- Publicly available sources. We may also obtain your information from professional networking sites, where you have actively published or submitted your information.
- Reference or word of mouth. A friend, former employer, colleague, or another official body may recommend you.
HOW WILL WE USE THE INFORMATION COLLECTED ABOUT YOU?
We will use your information in such ways to facilitate the coaching/training process and provide you with coaching/training services, including but not limited to:
- To provide our services by using your details to match your need and personality to the right coach /trainer but this does not constitute automated decision making);
- To make you aware of current coaching/training opportunities that may suit your requirements;
- To contact and update you about enquiries you have made or coaching or training you may have undertaken;
- To share your details with Coaches/trainers associated with The Wellbeing & Performance Company Ltd only.
If you agree to coaching /training, we may ask you during your sessions for further information. This is likely to come directly from you but may also be from third parties such as your employer for example.
We may also be required to share your data with third parties, for example:
- Our IT and CRM providers
We may also analyse the data internally so that we can offer a more relevant service, for marketing and strategic development purposes or for research purposes to improve our service.
HOW AND WHEN WILL WE CONTACT YOU?
We may contact you by phone, email or social media. Some examples of when we will contact you are:
- Upon receipt of an enquiry or your personal data, it will be reviewed to determine whether we are likely to be able to provide you with coaching or training services and we will notify you if you are added to our database.
- When one of our coaches/trainers considers you for a suitable for a coaching or training opportunity or to find out more about the coaching/training need that you have.
- Before we put you intouch with a coach or trainer.
- During and following any coaching and training that we may provide
- In relation to any correspondence we receive from you.
- To update you on any material changes to our policies and practices.
WHO WILL WE SHARE YOUR INFORMATION WITH?
In order to provide the right services to you, it is necessary for us to share your personal data with our carefully selected coaches and trainers (independent data controllers) who have the necessary qualifications to help you achieve. Once your data has been shared with them, they will determine how they use, store and process your data and will have their own privacy policy.
There may also be circumstances where disclosure is required or permitted by law (Doctors, Medical bodies). As an example, we are under an obligation to report serious medical concerns to your doctor (ie Suicidal thughts).
Generally, we will process your information within The Wellbeing and Performance Group Ltd. There may be occasions where we use third parties to process your information on our behalf. In such situations, these third parties will be under strict instructions and they will not be permitted to use your information for their own business purposes.
WILL WE TRANSFER YOUR DATA OUTSIDE THE EEA?
The Wellbeing & Performance Group Ltd is based in the UK and our back-up systems are stored in the EEA. We do not generally transfer your data out of the EEA. In the event that we do need to make transfers to countries outside the EEA, we will ensure the appropriate safeguards are in place.
HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?
The Wellbeing & Performance Group Ltd will only retain information for as long as necessary for the relevant activity. This may be determined by legislation or a decision as to what we consider necessary for the business based on a number of factors:
- If you have not registered with us, your data will be retained for 2 years from when it was added to our database or from when you were last contacted. You can request to have your record deleted (see below).
- If you do register with us, your data will be retained for 3 years from the last contact or activity on your record. You can request to have your record deleted (see below).
- Client contact details are retained for 3 years. You can request to have your record deleted (see below).
WILL WE PROCESS SPECIAL CATEGORIES OF PERSONAL DATA
We avoid processing special categories of data, these are sensitive personal data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
WILL WE CONTACT YOU FOR MARKETING PURPOSES?
We will only send you direct marketing emails that promote our company or services if you have opted-in to this via our website, where there is a copy of our Privacy Notice.
You can also manage your direct marketing preferences by contacting a Wellbeing & Performance Ltd representative, updating your preferences or clicking the unsubscribe link on an email.
To clarify, contacting you about specific coaching/training opportunities that you have requested is not marketing because we are not advertising or marketing our services.
CAN YOU REFUSE TO PROVIDE YOUR DATA TO US OR REQUEST THAT WE DELETE YOUR DATA?
If you do not provide the personal data requested, or use your right to withdraw your consent for the processing of your sensitive personal data, we may not be able to match you with suitable coaches or trainers.
You have the right to object to us processing your data based on legitimate interest. If you have not undertaken any coaching or training, then we will be able to delete your data.
You will have the option to delete your data by emailing dataprotection@TWPC.CO.UK
You do also have the right to restrict processing which means that we will stop further use of your data but still store it. However, if we stop processing your data it will mean that any coaching/training sessions you may currently be on will be terminated immediately.
Please note that we may require you to provide us with proof of your identity and answer security questions before processing your request and if your data is deleted we will have no record and you may be contacted again in the future.
CAN YOU FIND OUT WHAT DATA WE HOLD ABOUT YOU?
You have the right to be informed and access a copy of the information comprised in your personal data. If any of the data we hold is inaccurate, you have the right to rectify it. You can contact us at dataprotection@twpc.co.uk or your consultant directly to update your data.
You can make a request to find out what personal data we hold about you. You may exercise this right by making a written subject access request (SAR) to dataprotection@twpc.co.uk
We require you to provide us with proof of your identity and we may ask you to answer security questions before processing your request.
We usually act on such requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.
DO YOU HAVE THE RIGHT TO DATA PORTABILITY?
The GDPR introduces a new right to data portability.
The individual shall have the right to receive personal data concerning him or her, which he or she has provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit that data to another data controller in circumstances where:
- The processing is based on the individual’s consent or a contract; and
- The processing is carried out by automated means.
Where feasible, the Company will send the personal data to a named third party on the individual’s request.
OTHER WEBSITES
There may be links from our website to other websites. This privacy policy only applies to this site and not to any other website including any website linked from any part of the site. Accessing those third party websites or sources requires you to leave the site. We do not control those third party websites or any of the content they contain and you expressly acknowledge and agree that we are in no way responsible or liable for any of those third party websites, including, without limitation, the content, policies, failures, promotions, products, services or actions of those websites and/or any damages, losses, failures or problems caused by, related to or arising from those website. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each website that you visit.
COOKIES AND TRACKING SOFTWARE
We use “cookies” and other types of tracking software in order to personalise your visit to our website and enhance your experience by gaining a better understanding of your particular interests and customising our pages for you. A cookie is a message given to a web browser by a web server and which is then stored by the browser in a text file. Each time the browser requests a page from the server this message is sent back which enables the user’s computer to be identified.
We may use the information provided by cookies to analyse trends, administer the website, or for research and marketing purposes to help us better serve you. No information, which personally identifies you, will be collected through the cookies. If you like, you can set your browser to notify you before you receive a cookie so you have the chance to accept it and you can also set your browser to turn off all cookies. The website www.allaboutcookies.org (run by the Interactive Marketing Bureau) contains step-by-step guidance on how cookies can be switched off by users.
Our website requires the use of cookies in order to work at its best. If you do not wish these cookies to be used then please note that you may not experience our site working to its best effect.
Please note that when anyone visits any part of our website, we automatically collect certain non-personal information such as the type of computer operating system (e.g., Windows or Mac OS) and browser (e.g., Safari, Netscape, Internet Explorer) being used, and the domain name of the internet service provider. We sometimes use the non-personal information that we collect to improve the design and content of the site and to enable us to personalise your experience.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to change our Privacy Notice at any time. Changes to our Privacy Notice will be displayed on our website.
COMPLAINTS
If you have any issues or concerns then we ask that in the first instance you set this out in writing and send this to dataprotection@TWPC.co.uk
If we are unable to satisfactorily deal with your complaint you can complain to the ICO, which is the UK supervisory authority. You have the right to claim compensation for damages caused by a breach of data protection legislation.
