Future of Coaching Collaboration (FCC) Group (“FCC”, “we”, “us”) is committed to protecting and respecting your privacy and complying with the principles of the Data Protection Act and UK General Data Protection Regulation (GDPR). This policy sets out the basis on which any personal data we collect from you, or that you provide to us through your use of our website, 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 data controller is FCC, 47 St Georges Ave, London N70AJ, United Kingdom. This means FCC alone determines how your personal data will be used in relation to services we provide to you. As a not-for-profit organisation the FCC is exempt from formally registering with the ICO. However, we adhere to the principles of GDPR.
We are committed to processing information about you fairly and in a transparent manner and the aim of this document is to provide you with sufficient information for you to be able to understand what we are doing with your data. If you are unsure how we are handling information about you or you think we could improve our privacy information please let us know.
This policy only applies to our website and communications we have with you directly. If you leave our site via a link or otherwise, you will be subject to the policy of that website provider. We have no control over that policy or the terms of the website and you should check their policy before continuing to access the site.
1.2. Use Of This Policy
- Arranging into sections;
- Providing clear examples to show how the policies may be implemented by FCC;
- Outlining what your rights are around these policies.
1.3. Changes To This Policy
2. YOUR DATA
2.1. What Personal Data We Hold On You
Depending on the collaboration level at which you interact with the FCC, we may hold the following personal data on you:
- Addresses (current and past)
- E-mail addresses
- Telephone numbers
- Correspondence between us if you contact us
- Details of your role
- Details of your professional qualification and experience
- General communication we may have with you
- Relationships, including organisations and affiliations
- Information on your social media profiles where you follow us
- Data acquired by third parties that we share data with, for more info please see 2.6
2.2. The Purpose For Having It And Our Legal Reason For Doing So
We will use all the information provided to build a profile of you to be used in our communications with you.
|What we use your information for
|Our reason for having your personal data
|Our legitimate interest
|Connecting you to our professional activities
|Updating you on our professional activities Your consent to ongoing contact Your consent to being named in our activities where you have significantly contributed Your consent to cookies
|Keeping our records up to date Developing new ideas Seeking your consent when we need it to contact you
Being efficient about how we fulfil our legal duties
Sending electronic communications
Building up a profile regarding you
Having appropriate security and safeguards
2.3. How Long We Keep It For
We will hold information about you in our database for no more than is necessary. This means if you have actively become involved with the FCC (and have not notified us that you no longer wish to be involved), we will hold your data for a period of up to six years.
Once your records exceed the necessary retention period we will either anonymize them through pseudonymization or delete them securely. Pseudonymization is a procedure by which the most identifying fields within a data record are replaced by one or more artificial identifiers, or pseudonyms. There can be a single pseudonym for a collection of replaced fields or a pseudonym per replaced field. This means all your personal data is deleted and we keep only your transaction information for compliance and record keeping.
We may also contact you where we have consent or legitimate interest before we anonymize your record to see if you would still like to be kept informed about FCC activities.
FCC will hold the data on the above schedule unless:
- You ask us to remove it;
- We believe that you are no longer interested in our activities;
- We no longer need it for the purposes it was collected.
We always think about your best interests when we apply retention rules to our systems and are always happy to remove you at your request.
If you have any questions on how long we keep your data please contact us (section 6)
2.4. How We Secure And Maintain It
Unfortunately, the transmission of information via the internet is not completely secure and although we will do our best to protect your personal data transmitted to us via the internet we cannot guarantee the security of your data transmitted to the FCC website from your device: any transmission is at your own risk.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the FCC website or other online portals, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
2.5. Necessary Processors
FCC maintains a small core operations team. In order to achieve operational efficiency and resilience, we work with some of the best third parties.
This means the information we receive from you may pass through third party infrastructure to get to us and may ultimately be stored on third party infrastructure.
Each of our infrastructure partners is carefully reviewed and maintains the same security and standards towards data privacy as we do.
These are outlined below.
|Name of Organisation
|Google (G Suite)
|G Suite applications including email and web forms, cloud-based data storage
|Microsoft (Microsoft Office 365)
|Microsoft Office applications, cloud-based data storage
|Website management, usage and uptime statistics
2.6. Who We Share It With And How
We may disclose your personal information to third parties:
- If we are under a duty to disclose or share your personal data to comply with any legal obligation;
- To fulfil any service that you request from us (e.g. enquiry via our website etc.);
- To protect the rights, property, or safety of Executive Coaching Edge, our clients, contractors, or others including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We will share information about you with government agencies and some of our suppliers who process data on our behalf to help us to provide services to you. The purposes of sharing your information with these government agencies and suppliers is to notify you of our services and work opportunities, to provide you with information that you have requested from us, for administration purposes and to comply with the law.
|Names / Categories of Organisation
|Processing of email and web forms
|Mayflower Disclosure Services Limited
|Processing of basic and standard disclosure checks to the Disclosure and Barring Service
|Disclosure and Barring Service, Disclosure Scotland
|Processing of basic and standard disclosure checks
|Processing of PAYE, NIC, VAT and other tax requirements to meet legal requirements, for you as a contractor or as our client
|Processing of UK company filing requirements for you as our client
|Executive Coaching Edge Clients and Potential Clients
|Tendering for assignments
|Executive Coaching Edge banking services providers
|Making payments to you
2.7. International Transfer Of Personal Data
3. YOUR RIGHTS & ACCESSING YOUR DATA
|Right of access
|You have the right of access to information we hold about or concerning you. If you would like to exercise this right you should email us at email@example.com For example: we could provide a copy of all your information in a CSV or PDF file.
|Right of rectification or erasure
|If you feel that any data that we hold about you is inaccurate you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where you can demonstrate that the data we hold is no longer needed by us, or if you withdraw the consent upon which our processing is based, or if you feel that we are unlawfully processing your data. Your right of rectification and erasure extends to anyone we have disclosed your personal information to and we will shall take all reasonable steps to inform those with whom we have shared your data about your request for erasure.
|Right to restriction of processing
|You have a right to request that we refrain from processing your data where you contest its accuracy, or the processing is unlawful and you have opposed its erasure, or where we don’t need to hold your data anymore but you need us to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal data.
|Right to portability
|You have a right to receive any personal data that you have provided to us in order to transfer it onto another data controller where the processing is based on consent and is carried out by automated means. This is called a data portability request.
|Right to object
|You have a right to object to our processing of your personal data. This includes the right to object to any direct marketing we may undertake and to any automated decisions based on profiling which we may carry out. This also includes the right to object to any processing based on legitimate interests, such as disclosure checking.
|Right to withdraw consent
|You have the right to withdraw your consent for the processing of your personal data where the processing is based on consent. You can do so by contacting our data privacy team and they will immediately mark our records accordingly, this will then take effect as soon as possible. Please be aware that some activities may already have left our system at time of consent withdrawal.
|Right of complaint
|You also have a right to lodge a complaint about any aspect of how we are handling your data with the UK’s Information Commissioner’s Office who can be contacted at www.ico.org.uk.
4. PROVISION OF THIRD PARTY DATA
You are responsible for informing and obtaining the consent of any third parties whose data you enter in to our website.
Details of the cookies used by our site and third party cookies associated with functions of our site are given below.
5.2. First Party Cookies
|What does it do
|This is a session cookie, used by our web server’s load balancer to track which web server to send the visitor to. Its purpose is to improve the performance of the website.
5.3. Third Party Cookies
|What does it do
|Short term tracking cookie (1 minute expiry)
|Short term tracking cookie (1 day expiry)
|Short term tracking cookie (6 hour expiry)
|Cookie tracking the immediate referrer to Twitter. In this case, the referrer will be florinconsulting.com
|Google tracking cookie
|APISID, HSID, NID, SAPISID, SID, SNID, SSID
|Google account login cookies
5.4. IP Address
We may collect information about your computer, including where available your IP address, geographic location (if you allow when prompted by your browser), operating system and browser type, for system administration when you access our website. We use this information for statistical data about our users’ browsing actions and patterns when they access our website.
6. CONTACTING FUTURE OF COACHING COLLABORATION
If you would like to find out more info about this policy or ask us any questions please contact our data protection officer (below).
Future of Coaching Collaboration has appointed a data protection officer, if you would like to contact them please email firstname.lastname@example.org. You should also use this contact email address for withdrawing consent or enabling your rights as a data subject.