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Privacy Policy – Killer Whale Coaching

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Introduction

Killer Whale Coaching ("we", "us" or "our") is committed to protecting your personal information and respecting your privacy.

This Privacy Policy explains how we collect, use, store and share personal data and the rights you have under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

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Who We Are

Business Name: Killer Whale Coaching
Website: www.killerwhalecoaching.co.uk
Email: sorcha@killerwhalecoaching.co.uk

Killer Whale Coaching provides professional coaching services to individuals and to clients introduced through their organisations.

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What Personal Data We Collect

Depending on your relationship with us and the coaching services provided, we may collect and process:

  • Names and contact details

  • Information provided during coaching sessions

  • Records of meetings, coaching sessions and decisions

  • Notes relating to coaching sessions

  • Audio or video recordings of calls or coaching sessions, where you have consented to recording

  • Email correspondence and other communications

  • Appointment and scheduling information

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Coaching sessions may naturally involve clients discussing personal matters. We will only record information that is appropriate and relevant to the provision of our coaching services.

Why We Collect and Use Personal Data

We collect and use personal information primarily to provide professional coaching services.

This may include using information to:

  • Arrange and manage coaching sessions

  • Communicate with clients

  • Maintain appropriate coaching notes and records

  • Understand a client's objectives and provide continuity between sessions

  • Conduct and, where expressly agreed, record remote coaching sessions

  • Maintain records of meetings and decisions

  • Manage our professional relationship with clients

  • Maintain appropriate business and accounting records

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Our coaching records are maintained for the purpose of providing coaching services in accordance with the professional principles and standards applicable to our work, including those of the International Coaching Federation where relevant.

Lawful Bases for Processing

The lawful basis identified for processing personal information is:

  • Consent – where you have given us permission to collect and use your personal information for a particular purpose.

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Where we record or transcribe a coaching session using services such as Fyxer, Otter or Zoom, we will obtain the client's consent before recording.

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Where consent is our lawful basis, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect processing that took place before consent was withdrawn.

 

Depending on the nature of a particular engagement, another lawful basis may also apply – for example, where processing is necessary to perform a contract with an individual client. Where appropriate, we will ensure the correct lawful basis is identified before processing takes place.

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Coaching Notes and Confidentiality

Information shared during coaching sessions is treated as confidential and is used to enable us to provide an effective and consistent coaching service.

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We may maintain notes of coaching discussions so that we can provide continuity between sessions and appropriately support the client's coaching objectives.

Where technology is used to create notes or transcripts, we will tell clients about this and obtain consent where required.

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We aim to collect only information that is relevant to the coaching relationship and will protect coaching records against inappropriate access or disclosure.

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Where We Obtain Personal Data

We obtain personal information primarily:

  • Directly from our clients during communications and coaching sessions

  • From organisations that engage us to provide coaching services to members of their staff

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Where an organisation introduces an employee or other individual to us for coaching, we may initially receive information such as their name, business contact details and introductory information required to arrange the coaching relationship.

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We do not otherwise routinely obtain information about clients from unrelated third parties.

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Sub-Processors and Systems

We use third-party systems and service providers to support our business and the delivery of coaching services. These include:

  • Fyxer – note-taking and recording of calls, where the client has consented

  • Otter – note-taking, transcription and recording of calls or coaching sessions, where the client has consented

  • FreeAgent – accounting and financial administration

  • Microsoft Outlook – email, contacts and calendar management

  • Zoom – online coaching calls and occasional recording of sessions, where the client has consented

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These providers may process personal information on our behalf in order to provide their respective services.

 

We take reasonable steps to use reputable service providers and expect processors handling personal data on our behalf to provide appropriate contractual, organisational and technical safeguards.

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Access by Administrative Support

Our Personal Assistant (PA) has access to our email mailbox and calendar for legitimate administrative purposes.

This means the PA may have access to limited personal information contained within emails, contact details and appointment records.

 

Access is limited to what is reasonably necessary to provide administrative support and personal information must be handled confidentially and appropriately.

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Sharing Personal Data

We do not sell personal information.

Personal information may be shared with:

  • Our PA, where necessary for administrative support

  • Organisations providing technology and administrative services on our behalf, including the systems described above

  • Professional or legal advisers where necessary

  • Regulatory or legal authorities where we are required by law to disclose information

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Where an organisation has commissioned coaching for a member of its staff, this does not mean that information discussed during coaching sessions will automatically be disclosed back to that organisation. Any such sharing will be handled in accordance with the agreed coaching arrangements, confidentiality requirements and applicable data protection law.

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International Data Transfers

Although we do not intentionally send client information overseas as part of our coaching activities, some of the technology providers we use may process, access or store personal information outside the UK.

 

This may apply to services such as Fyxer, Otter, Microsoft and Zoom, depending on the service configuration, infrastructure and sub-processors involved.

 

Where personal information is transferred outside the UK, we will ensure that an appropriate lawful transfer mechanism is in place. Depending on the destination and circumstances, this may include:

  • UK adequacy regulations;

  • the UK International Data Transfer Agreement (IDTA);

  • the UK Addendum to the EU Standard Contractual Clauses (SCCs);

  • applicable Standard Contractual Clauses; or

  • another legally recognised international data transfer mechanism.

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Where appropriate, additional technical, contractual or organisational safeguards will also be used to protect personal information.

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Data Retention

We retain personal information only for as long as it is reasonably necessary for the purposes for which it was collected.

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Retention periods will take account of:

  • The duration of the coaching relationship

  • Professional and contractual requirements

  • Accounting and financial record-keeping requirements

  • Applicable legal obligations

  • The nature and sensitivity of the information

  • The establishment, exercise or defence of legal claims

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Recordings and transcripts should not be retained indefinitely and will be deleted when they are no longer reasonably required for the purpose for which they were created.

Information that is no longer required will be securely deleted, destroyed or anonymised.

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Data Security

We take appropriate technical and organisational measures to protect personal information from accidental loss, unauthorised access, alteration, disclosure or destruction.

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These measures may include:

  • Password-protected systems and accounts

  • Appropriate access controls

  • Limiting access to coaching records to people who reasonably require it

  • Security controls provided by our technology suppliers

  • Appropriate confidentiality arrangements for administrative support

  • Secure management of emails, calendars and coaching records

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Marketing

We will only use personal information for direct marketing where we have an appropriate lawful basis to do so.

Where marketing is based on consent, you may withdraw that consent at any time.

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You can ask us to stop sending marketing communications by contacting sorcha@killerwhalecoaching.co.uk.

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Your Data Protection Rights

Depending on the circumstances, UK data protection law gives you rights including:

  • The right to be informed about how your personal information is used

  • The right to access personal information we hold about you

  • The right to have inaccurate or incomplete information corrected

  • The right to request deletion of your personal information in certain circumstances

  • The right to request restriction of processing

  • The right to object to certain types of processing

  • The right to data portability where applicable

  • The right to withdraw consent where processing is based on consent

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These rights are not absolute and may depend on the circumstances and the lawful basis on which information is processed.

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To exercise your rights, please contact sorcha@killerwhalecoaching.co.uk.

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How to Complain

If you have concerns about how we use your personal information, please contact us first so that we have an opportunity to investigate and address your concerns:

 

Killer Whale Coaching

Email: sorcha@killerwhalecoaching.co.uk

 

You also have the right to complain to the UK's independent data protection regulator:

Information Commissioner's Office (ICO)
Website: https://www.ico.org.uk
Telephone: 0303 123 1113

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Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our services, systems, suppliers or legal obligations.

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The latest version will be made available through our website.

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