Effective: January 2024

I value your privacy and am committed to protecting your personal information. This privacy policy explains how I collect, use and safeguard your personal data when you engage in coaching sessions, or when you add your name to my waitlist.  Please read this policy carefully to understand my practices regarding your personal information.  I may update this policy from time to time and, if I make any material changes, I will notify you when I do so. I will provide you with the opportunity to review such changes.  By continuing to use my services after the changes have been made and I have notified you of them, the way I use your personal data will be subject to the terms of the updated policy.

This policy covers:

1. Who I am;

2. What personal data I hold and how I get it;

3. What I use your personal data for;

4. Sharing your personal data;

5. Retention;

6. Data security and transfers; and

7. Your rights.

If you have any further questions about how I process your information, please don’t hesitate to get in touch by contacting me at coaching@sophiemiller.co.uk.

1. Who I am

My services are delivered by myself, Sophie Miller. I primarily work virtually and am located in London, UK. 

2. What personal data I hold and how I get it

I use your personal data so that I can provide my services to you, or in the case of my waitlist, so that I can contact you regarding my services.

Personal details

When you register with me or on my waitlist, you complete forms and provide me with basic information about yourself, such as your name, email, date of birth, address, professional industry, function and level. You are responsible for the accuracy of the information that you provide to me.

I may also collect other sensitive personal information about you or other details which you may share with me at your discretion during the provision of my services.

Information

The main type of information I hold about you is: information about your reasons for seeking coaching, goals and progression. This includes details of your consultations with me, and interactions with my digital services.  This also includes your name and contact information.

I get some of this information directly from you, when you register with me and when you use my services. I do not collect data about you from publicly available sources.

I retain brief notes of my consultations and interactions with you. These notes are held securely in accordance with my retention policy. Please refer to the ‘Retention Periods’ section of this policy. 

Some of this information is considered ‘sensitive’ personal information and as such, slightly stricter data protection will apply. Where required by law, I will obtain your explicit consent before I use it.

3. What I use your personal data for

The purposes for which I use your personal data and the legal grounds on which I do so are as follows:

Providing you a service

• I obtain and use your personal details in order to respond to initial contact from you;

• I obtain and use your personal details in order to establish and deliver my contract with you and (if applicable);

• I obtain and use your information because this is necessary for coaching purposes, including the provision of coaching services. This includes the information collected through my consultations with you (such as notes and recordings). It may also include sharing information with other coaches as necessary for the provision of services to you. 

• I do not sell your data to any third party provider.

Improving professional coaching

• Where you have provided your explicit consent, I may use your information (always having removed personal identifiers, such as your name or other identifying details) to improve my products and services, so that I can deliver better services to you and other users. Strict confidentiality and data security provisions apply at all times. This consent relates to information that can identify you.

Keeping you up to date

• I use your email address, phone number and/or details to contact you or present you with occasional updates and marketing messages where you have not opted out, based on my legitimate interest in marketing my services to you and subject to your right to opt out at any time.

• As part of providing you with high quality professional coaching services, I may contact you by SMS, email and/or other means to offer you helpful information or invite you to make appointments, use training modules or other resources.

Other uses

• I may also use your personal information for other business purposes such as data analysis, identifying usage trends, creating anonymised data sets for research, statistics and analytics purposes, creating knowledge pieces (such as white papers), determining the effectiveness of my services, and/or to enhance, customise, and improve my features, products and services.

• I may send you information (such as reports, promotions, research, white papers, events and general information about, for example, relevant industry sectors) that I think you may find interesting (in each case, in accordance with your marketing preferences).

• Where necessary, I may need to share personal details for the purposes of fraud or unlawful behaviour prevention and detection, or when there is evidence of serious danger or harm to be incurred if the information is not shared.

• I also store your information, such as notes from consultations or sessions with you as well as your interactions with my digital services including interactions with my live chat services, support services, use of tools, for safety, regulatory and compliance purposes.

• Where necessary for safety, regulatory and/or compliance purposes, I may audit consultations and your other interactions with my services. Strict confidentiality and data security provisions will apply at all times to any such audit and access.

4. Sharing your personal data with others

• I may share your personal data with members of my corporate group and my partners. This is to help me deliver my services to you.

• I may share your personal data with companies I have hired to provide services on my behalf, including those who act as data processors on my behalf, acting strictly under contract in accordance with applicable data protection legislation. Those data processors are bound by strict confidentiality and data security provisions, and they can only use your data in the ways specified by me.

• Where you access my services through any of my commercial partners (including your employer) I may share with such partner your name, and the fact you have registered/used the service (and any other similar information). I will not, without your consent, share any details relating to the content of your consultation with me.

5. Retention periods

I will retain information I collect from you where I have an ongoing legitimate business need to do so (for example, to provide you with the services or to comply with applicable legal, tax, insurance or accounting requirements).

When I have no ongoing legitimate business need to process your personal information, I will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then I will securely store your personal information and isolate it from any further processing until deletion is possible.

When determining the relevant retention periods I will take into account the following factors:

• My contractual obligations and rights in relation to the information involved;

• Legal obligations under applicable law to retain data for a certain period of time;

• My legitimate interest where I have carried out a balancing test;

• Statute of limitations under applicable law(s);

• Potential disputes;

• If you have made a request to have your information deleted;

• Guidelines issued by relevant data protection authorities.

• Otherwise, I securely erase your information once this is no longer needed.

If you have any questions about how long I retain your personal information, you may contact me by emailing coaching@sophiemiller.co.uk.

6. Data security and transfers

Safeguarding personal data and respecting the confidentiality of your information is of paramount importance to me.

All information you provide to me is stored securely and I take necessary steps, including putting in place appropriate technical and organisational measures, to protect your personal data from loss, misuse, unauthorised access, disclosure, alteration and destruction. While I have technical and security measures in place to protect personal data under my control I cannot guarantee that loss, misuse, unauthorised access, disclosure, alteration or destruction will not occur. The measures I use are designed to provide a level of security appropriate to the risk of processing your personal information and to help ensure that your data is safe, secure and only available to you and to those with authorised access.

By submitting your personal data, you agree to this transfer, storing or processing. To find out more about how I safeguard your information as related to transfers please contact me by emailing coaching@sophiemiller.co.uk.

7. Your rights

By law, you have a number of rights when it comes to your personal data, as follows:

• The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how I use your information and your rights. This is why I am providing you with the information in this Policy.

• The right of access: You have the right to obtain access to your information (if I am processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that I am using your information in accordance with data protection law.

• The right to rectification: You are entitled to have your information corrected if it’s inaccurate or incomplete.

• The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for me to keep using it. This is not a general right to erasure; there are exceptions.

• The right to restrict processing: You have rights to ‘block’ or suppress further use of your information. When processing is restricted, I can still store your information, but may not use it further. I keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

• The right to data portability: You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between my IT systems and theirs safely and securely, without affecting its usability.

• The right to object to processing: You have the right to object to certain types of processing, including processing for direct marketing or if you no longer want to be contacted regarding search or coaching opportunities.

• The right to lodge a complaint: You have the right to lodge a complaint about the way I handle or process your personal data with your national data protection regulator.

• The right to withdraw consent: If you have given your consent to anything I do with your personal data, you have the right to withdraw your consent at any time (if you do however, it does not mean that anything I have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw any consent to me using your personal data for marketing purposes.

• I will act on requests and provide information free of charge and generally within one month from when I receive your request.

For further information, please contact me by emailing coaching@sophiemiller.co.uk and contact your local data protection authority. I will respond to all requests I receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

You may also contact the Information Commissioners Office (the data protection regulator in the UK): Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, telephone: 0303 123 1113 (local rate), or your local data protection authority.

By engaging in coaching sessions, adding your name to my waitlist or using my services, you acknowledge that you have read, understood, and agreed to the terms of this privacy policy.