Reach Outstanding – CLIENT DATA PROTECTION NOTICE MAY 2018
This Reach Outstanding Client Data Protection Notice (the “Notice”) sets out the personal data that we collect and process about REACH OUTSTANDING Clients, the purposes of the processing and the rights that you have in connection with it.
Types of personal data we collect
In the course of your coaching with REACH OUTSTANDING, we may process personal data about you. The types of personal data we process include, but are not limited to:
* Identification data e.g. name, gender, Client number
* Contact details e.g. home address, telephone/email, Skype ID
* Coaching notes from coaching calls or meetings
Sources of personal data
Usually you will have provided the information we hold about you but there may be situations where we collect personal data about you from other sources, namely social media or 360 surveys conducted for coaching purposes.
Purposes for processing personal data
REACH OUTSTANDING collects and uses your personal data primarily for the purpose of managing our coaching relationship with you.
REACH OUTSTANDING may also collect and use personal data when it is necessary for other legitimate purposes, such as to help us conduct our business more effectively and efficiently – for example, for IT security/management, accounting purposes, or financial planning.
REACH OUTSTANDING may also use your personal data where we consider it necessary for complying with laws and regulations, including collecting and disclosing Client personal data as required by law, under judicial authorization, or to exercise or defend the legal rights of the REACH OUTSTANDING.
REACH OUTSTANDING will carry out automated monitoring of its IT and communications systems through automated tools such as anti-malware software, website filtering and spam filtering.
Monitoring activities are likely to be continuous and ongoing. However, they will always be proportionate, for legitimate purposes, and as required or permitted by applicable law. Before undertaking any monitoring activities, we will consider your reasonable expectations of privacy and assess whether there are any less invasive options.
You should be aware that any message, files, data, document, facsimile, telephone connection metadata and fees, social media post or instant message communications, or any other types of information transmitted to or from, received or printed from, or created, stored or recorded on our IT and communications systems and assets are presumed to be business-related and may be monitored by us in accordance with applicable law.
Who we share personal data with
REACH OUTSTANDING will not share your personal data with any third party except in the below circumstances.
The International Coach Federation (to which Reach Outstanding belongs to) may, at times, conduct audit of the REACH OUSTANDING to ensure it maintains the ICF standards and may wish to contact clients of the company to ensure those standards are enforced. In those cases, explicit permission from the Client will be sought.
We may disclose personal data to other Third Parties on other lawful grounds, including:
• To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process, or to meet national security or law enforcement requests, including, but not limited to, a subpoena or search warrant;
• As necessary to establish, exercise or defend against potential, threatened or actual litigation;
• Where necessary to protect the vital interests of another legal entity or natural person; • In connection with the sale, assignment or other transfer of all or part of our business.
Transfer of personal data outside of the EEA
REACH OUSTANDING is a division of OurStillness FZ LLC, a company registered in Fujairah Free Zone. We may need to transfer personal data to or from other countries where we have a coaching relationship (for example if the Client is located in another country than REACH OUTSTANDING). When we export your personal data to a different country, we will take steps to ensure that such data exports comply with applicable laws, e.g. via EU Standard Contractual Clauses.
Data retention periods
Personal data will be stored for once year after the end of the coaching relationship between the Client and REACH OUTSTANDING.
During our coaching relationship, your personal data is stored and on encrypted hard disks that do not leave the premises of REACH OUSTANDING. No data is kept on shared drives of any kind, including “Cloud”.
Your data protection rights
If REACH OUTSTANDING is relying on your consent to process your personal data, you have the right to withdraw your consent at any time. This will not affect the lawfulness of the processing before its withdrawal.
You further have the right to lodge a complaint with a supervisory authority about our collection, processing and use of your personal data.
Updates to this Notice
This Notice may be updated periodically to reflect any necessary changes in our privacy practices. Where such changes will materially affect your privacy rights, we will inform you by a prominent notice on the corporate websites and indicate at the top of the Notice when it was most recently
updated. We encourage you to check back on this Notice periodically so that you are aware of the most recent version of it.
Questions and comments
You can address any questions or comments relating to this Notice to email@example.com.
You have a right to lodge any complaints with a data protection supervisory authority.