Virtual Coaching Partners (VCP) is an online business coaching portal and resource platform. In the course of its business it needs to collect and use certain types of information about the Individuals or Service Users who come into contact with VCP in order to carry on our work. This personal information must be collected and dealt with appropriately whether is collected on paper, stored in a computer database, or recorded on other material.
- Data Controller
VCP is the Data Controller under the General Data Protection Regulation (GDPR), which means that it determines what purposes personal information held, will be used for.
VCP will only use your data for the purpose of providing our services or to comply with our legal obligations and will not share your data with any third party, other than where necessary for the purpose of providing our services. We will only process your data according to one of the six lawful bases.
In the normal course of business we will primarily rely on two; these are:
- Consent: The data subject has freely given consent for their information to be processed for a specific purpose.
- Contract: Processing is necessary due to the fulfilment of a contract.
VCP regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal.
VCP intends to ensure that personal information is treated lawfully and correctly.
To this end, VCP will adhere to the Principles of Data Protection, as detailed in the General Data Protection Regulation, including that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; and
- processed in a manner that ensures appropriate security of the personal data
VCP will take reasonable and proportionate steps to:
- Observe fully conditions regarding the fair collection and use of information
- Meet its legal obligations to specify the purposes for which information is used
- Collect and process appropriate information, and only to the extent that it is needed to fulfil its operational needs or to comply with any legal requirements
- Ensure the quality of information used
- Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include:
- The right to be informed that processing is being undertaken,
- The right of access to one’s personal information
- The right to prevent processing in certain circumstances and
- The right to correct, rectify, block or erase information which is regarded as wrong information)
- Take appropriate technical and organisational security measures to safeguard personal information
- Ensure that personal information is not transferred abroad without suitable safeguards
- Treat people fairly
- Set out clear procedures for responding to requests for information
- Data collection
Informed consent is when
- An Individual/Service User clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data
- And then gives their consent.
VCP will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, on the internet, or by completing a form.
When collecting data, VCP will aim to ensure that the Individual/Service User understands why the information is needed, and what it will be used for.
- Data Storage
Information and records relating to service users will be stored securely and will only be accessible to authorised staff.
Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately.
- Data access and accuracy
All Individuals/Service Users have the right to access the information VCP holds about them. VCP will also take reasonable steps ensure that this information is kept up to date by asking data subjects whether there have been any changes.
In addition, VCP will take reasonable steps to ensure that:
- Everyone processing personal information understands that they are contractually responsible for following good data protection practice
- Everyone processing personal information is appropriately trained and supervised
- It deals promptly and courteously with any enquiries about handling personal information
- It describes clearly how it handles personal information
- It will regularly review and audit the ways it holds, manages and uses personal information
- All staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them
This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the GDPR.
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