Privacy Statement for Morgan O’Connell t/a Arrow Coaching
Morgan O’Connell t/a Arrow Coaching is committed to protecting and respecting your privacy. When I refer to ‘I’ it is Morgan O’Connell but using Arrow Coaching as a trading name. I wish to be transparent on how I process your data and show you that I am accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.
It is the intention of this privacy statement to explain to you the information practices of Arrow Coaching in relation to the information I collect about you.
For the purposes of the GDPR the data controller is:
Morgan O’Connell t/a Arrow Coaching.
Please read this Statement carefully as this sets out the basis on which any personal data I collect from you, or that you provide to me, will be processed by me.
Who I am
Morgan O’Connell (The Data Protection Officer) is a Financial and Career Coach, t/a Arrow Coaching.
My principal business is to provide career and financial coaching services to clients. To provide you with relevant information or respond to your requests I sometimes request that you provide me with information about yourself.
How I collect personal information
- When you give it to me
For example, personal information that you submit through my Website by making a booking, registering as a member or signing up for my email newsletter; or personal information that you give to me when you communicate with me by email, phone or letter.
- When it is available publicly
Your personal information may be available to me from external publicly available sources. For example, depending on your privacy settings for social media services, I may access information from those accounts or services (for example when you choose to interact with me via Facebook, LinkedIn, YouTube or Instagram).
- When you visit my Website
When you visit my Website, I automatically collect the following types of personal information:
- Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.
- Information about your visit to the Website, including the uniform resource locator (URL) clicks to, through and from the Website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.
- Some portions of my Website may request that you give me information about yourself, from which I am able to identify you, such as your name, email or other address. Some other ways in which may collect information from you are:
- Subscription to newsletters
- Planning content-related
- correspondence e.g. Event registrations for seminars, conferences, etc.
- White paper or other downloads
In general, I may combine your personal information from these different sources set out above, for the purposes set out in this Notice.
Why am I processing your data?
For me to provide you with coaching services Arrow Coaching may wish to collect personal data as outlined below. My reason (lawful reason) for processing your data under the GDPR is:
Legal basis – I intend to tell you why I am asking for the information and what I intend to do with it. You will have the option of not providing the information, in which case you may still be able to access other parts of this Website, although you may not be able to access certain services. Data will not be held for longer than is necessary. General client details will be held while you are availing of my services and will be retained for a period of 3 years after the relationship is terminated. The information I request about you may also be used to verify your identity, send you information or contact you in relation to an Arrow Coaching service that you are using or that I believe may be of interest to you after you have chosen to ‘opt in’ to, if appropriate.
Sharing information with third parties
If I wish to pass your sensitive personal data onto a third party I will only do so once I have obtained your explicit consent, unless I am legally required to do otherwise. The exception to this, as outlined in the Arrow Coaching agreement, is if maintaining confidentiality during the time you use my services is likely to endanger you, me or a third party.
Arrow Coaching’s intent is to strictly protect the security of your personal information; honour your choice for its intended use; and carefully protect your data from loss, misuse, unauthorised access or disclosure, alteration or destruction.
However, you should always take into consideration that the internet is an open forum and that data may flow across networks with little or no security measures, and therefore such information may be accessed by people other than those you intended to access it. In any event, I am committed to ensuring that the information I collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
How will Arrow Coaching use the personal data it collects about you?
Arrow Coaching will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). I will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
Special Categories of personal data
If I collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin – financial information is not classified as special categories of personal data) – I will obtain your explicit consent
I use information held about you in the following ways:
- To ensure that content from Arrow Coaching is presented in the most effective manner for you and for your computer
- To provide you with information, products or services that you request from me
- To register you as a client of Arrow Coaching
- To allow you to make a booking to use my facilities or services or request information or quote
- To analyse and improve my work, services, activities, products or information (including website)
- To audit and administer my accounts
- to satisfy legal obligations which are binding on me, for example in relation to regulatory, government and/or law enforcement bodies with whom I may work (for example requirements relating to the payment of tax or anti-money laundering)
- Fraud prevention
- For the establishment, defence and/or enforcement of legal claims
- To provide you with information regarding our other products or services which I feel may interest you. I may use your email address for this purpose and to send you updates or news regarding Arrow Coaching services
- To provide you with information regarding products or services of third parties which I feel may interest you and where you have consented to be contacted for such purposes
- To carry out my obligations arising from any contracts entered between you and me
- To deliver and maintain a high-quality service
- To allow you to access the Arrow Coaching Website and to participate in interactive features of our service, when you choose to do so
- To notify you about changes to my services, any Arrow Coaching product or to the Arrow Coaching Website.
How to update and/or amend the personal information you have provided
You are entitled to know whether I hold information about you and, if I do to have access to that information and have it corrected if it is inaccurate or out of date. To exercise your Right of Access or to update your details under your Right of Rectification or Erasure please email your request to the [email protected]
Your rights as a data subject
At any point while I am in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access– you have the right to request a copy of the information that I hold about you
- Right of rectification– you have a right to correct data that I hold about you that is inaccurate or incomplete
- Right to be forgotten– in certain circumstances you can ask for the data I hold about you to be erased from my records
- Right to restriction of processing– where certain conditions apply to have a right to restrict the processing.
- Right of portability– you have the right to have the data I hold about you transferred to another organisation.
- Right to object– you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling– you also have the right to object to the legal effects of automated processing or profiling
- Right to judicial review:if I refuse your request under rights of access, I will provide you with a reason as to why.
If you wish to make a complaint about how your personal data is being processed by Arrow Coaching, you have the right to lodge a complaint directly to [email protected]
Failure to provide further information
If I am collecting your data for a contract between us and you cannot provide this data, the consequences of this could mean the contract cannot be completed or details are incorrect.