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Windlesham Wellbeing Privacy and Data Policies

What We Do: 

We provide nutritional coaching and Energy Alignment Method mentoring and coaching to empower clients to optimise their health by optimising any or all of the following: their nutrition, energetic alignment, well-being, and energetic flow. We focus on optimising physical, emotional, mental, spiritual, and energetic health through group-based and/or personalised one-to-one coaching (the “Purpose”).

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Personal Data

 How We Obtain Your Personal Data:

Information provided by you 

You provide us with personal data in the following ways: 

  • by completing the Client Information Form; 

  • by signing a Coaching Agreement form; 

  • during one-to-one or group-based coaching and mentoring sessions; 

  • through email, over the telephone, by post or via social media; 

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This may include the following information: 

  • basic details such as name, address, contact details and emergency contact details; 

  • details of contact we have had with you such as referrals and appointment requests; 

  • health information including your previous medical history and lifestyle habits; 

  • Personal information about your life situation, circumstances, thoughts, beliefs, emotions and feelings and any trauma. 

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We use this information in order to provide you with nutritional coaching and/or Energy Alignment Method mentoring and coaching. This means that the legal basis of our holding your personal data is for legitimate interest.   

Following completion of your nutritional coaching and/or Energy Alignment Method mentoring and coaching services we retain your personal data for as long as needed and permitted in the light of the Purpose. This also enables us to process any complaint you may make. In this case the legal basis of our holding your personal data is for contract administration. 

How we use your personal data 

We use this personal information for purposes of administering our business activities, providing you with the best possible sessions, customer service and making available other items and services to our customers and prospective customers.  

We undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with our duty of professional confidence and the requirements of the General Data Protection Regulation (“GDPR”) concerning data protection. We will also take reasonable security measures to protect your personal data storage. 

We may use your personal data where there is an overriding public interest in using the information, e.g. in order to safeguard an individual, or to prevent a serious crime. Also, where there is a legal requirement such as a formal court order. We may use your data for marketing purposes such as newsletters or social media articles, but this would be subject to you giving us your express consent. 

Sharing Information

We will keep information about you confidential. We will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties: 

  • any contractors and advisors that provide a service to us or act as our agents on the understanding that they keep the information confidential; 

  • anyone to whom we may transfer our rights and duties under any agreement we have with you; 

  • any legal or crime prevention agencies and/or to satisfy any regulatory request, if we have a duty to do so or if the law allows us to do so. This would include social services should any safeguarding issues are disclosed. 

We will seek your express consent before sharing your information with your GP or other healthcare providers. However, if we believe that your life is in danger then we may pass your information onto an appropriate authority (such as the ambulance service or your GP, or social services) using the legal basis of vital interests. 

Emails

We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties, and we will not provide your personal information to any third party individual, government agency, or company at any time unless strictly compelled to do so by law. 

Your Protection
Rights

Every individual has the right to see, amend, delete or have a copy of, data held that can identify you, with some exceptions. You do not need to give a reason to see your data.  

If you want to access your data you must make a subject access request in writing to jobrimmell@gamail.com Under special circumstances, some information may be withheld. We shall respond within 20 working days from the point of receiving the request and all necessary information from you. Our response will include the details of the personal data we hold on you including: 

  • sources from which we acquired the information; 

  • the purposes of processing the information; 

  • persons or entities with whom we are sharing the information. 

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Under data protection law, you have rights including: 

Your right of access - You have the right to ask us for copies of your personal information.  

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.  

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.  

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.  

Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances. 

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. 

You are not required to pay any charge for exercising your rights.  

We do not carry out any automated processing, which may lead to automated decision based on your personal data.  

If you would like to invoke any of the above rights, please write to Jo Brimmell or email jobrimmell@gmail.com

Safeguarding
Security

We only use information that may identify you in accordance with GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and any processing must be fair and lawful.  

Within the mentoring and coaching sector, we also have to follow the common law duty of confidence, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing the nutritional coaching and/or Energy Alignment Method mentoring and coaching services. We will protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.  

We also ensure the information we hold is kept in secure locations, and restrict access to information to authorised personnel only. 

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Holding Information

We will retain your personal information for as long as needed or permitted in light of the Purpose for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the service to you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations and litigation). 

Complaints

If you have a complaint regarding the use of your personal data, please contact us by writing to Jo Brimmell at jobrimmell@yahoo.co.uk  and we will do our best to help you. 

You can also complain to the ICO if you are unhappy with how we have used your data. 

The ICO’s address:             

Information Commissioner’s Office 

Wycliffe House 

Water Lane 

Wilmslow 

Cheshire 

SK9 5AF 

 

ICO Helpline number: 0303 123 1113            ICO website: https://www.ico.org.uk 

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