Who we are
Brightspace Thinking Ltd is a private company limited by shares and registered in England and Wales. Our website address is https://brightspacethinking.co.uk
This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.
We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected.
What personal data we collect
We collect the information needed to provide our core services of coaching, leadership development & coaching supervision. This includes name, email address, telephone number and postal address. You don’t have to disclose any of this information, however, if you do choose to withhold requested information, we may not be able to provide you with certain services in full.
If you make a booking, we will store the details you provide. This may include special personal information (about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) only if you choose to share it.
In addition handwritten paper records may be kept of the topics discussed in coaching sessions.
What do we do with the data
We will use the information you provide to:
- Fulfil our contractual obligations to you e.g. sending information about your booking, scheduling meetings and reviewing notes to prepare for coaching sessions.
- Process invoices, payments and verify financial transactions
- Record any contact we have with you
- Maintain a database of coaching hours undertaken in which only the client name is recorded, to meet professional coaching accreditation requirements.
- Provide you with information that we think may be of interest to you, only if you have agreed to it.
We will not use your information for marketing purposes unless you have opted in to receive this through our website and / or subscribed to receive our blog. You can opt out of receiving this at any time, by writing to email@example.com.
We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.
For example, we may aggregate profile data to assess interest in a product or service.
However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The cookies used on our website do not store personal data. You can find out more about the cookies used on our website here.
Sharing your data
We will not share your data with any third parties unless;
- We are required by law to do so
- We need to do so in order to fulfill our contractual obligations to you. For example, for the purposes of administering a psychometric assessment
- The 3rd party provider for our booking system
Our coaches have regular supervision sessions with qualified and experienced supervisors, in which they discuss any ethical or other challenges arising during their work. Personal information is disclosed during these sessions only to the extent necessary to allow the supervisor to perform their role, and no personal data is shared in written or electronic form, nor are any notes containing personal data retained by the supervisor.
Where we send your data
The computers and servers on which Brightspace stores data are located in the UK or the European Union.
Website visitor comments may be checked through an automated spam detection service.
We may transfer data to other reputable third party organisations as explained above – these may be situated inside or outside the European Economic Area.
How we protect your data
We place great importance on the security of all our clients’ personally identifiable information and have technical and organisational measures in place to attempt to protect against the loss, misuse and alteration of personal data in our possession. For example, we store all data on secure servers and databases are encrypted. Paper files are stored securely and only identifiable by initials.
We will not usually send sensitive personal information by email; however, if you choose to send information of this nature to us we will do our best to protect it. Clients should be aware that the transmission of data across the internet is not completely secure.
Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: firstname.lastname@example.org.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How long we will store your data
Coaching session notes and your personal information are stored for a maximum of 3 years after our professional relationship ends and then destroyed securely.
The record of hours of coaching we deliver to you will be held in our database until you ask for it to be deleted.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
If you leave a comment on our website, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
What rights you have over your data
You have the following rights in relation to your Data:
- Right to access– the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
- Right to correct– the right to have your data rectified if it is inaccurate or incomplete.
- Right to erase– the right to request that we delete or remove your data from our systems.
- Right to restrict our use of your data– the right to “block” us from using your data or limit the way in which we can use it.
- Right to data portability– the right to request that we move, copy or transfer your data.
- Right to object– the right to object to our use of your data including where we use it for our legitimate interests.
To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your data (where consent is our legal basis for processing your data), please contact us via this e-mail address: email@example.com
If you are not satisfied with the way a complaint you make in relation to your data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
It is important that the data we hold about you is accurate and current. Please keep us informed if your data changes during the period for which we hold it.
Links to other websites
Brightspace’s website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave the site, you should note that Brightspace does not have any control over that other website and therefore cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites. This privacy statement does not govern such sites. You should exercise caution and look at the privacy statement applicable to the website in question.
Changes to this privacy notice
Brightspace keeps this privacy notice under regular review. It was last updated on 21st January 2021
By using our website or providing your information you consent to our collection and use of the information you provide in the way(s) set out in this policy. If you do not agree to this policy please do not use our site.
How to Contact Brightspace
If you have any questions about this privacy statement please email firstname.lastname@example.org