Last updated: 19th July 2018
Who we are
We are Challenge U Change U Ltd. A professional coaching and consulting company specialising in the areas of Life and Career Pivots, Redundancy and Retirement Coaching.
Our website address is: www.paulineharley.com
Challenge U Change U Ltd is committed to the safety and proper use of the data entrusted to us, according to Data Protection law and regulations. This includes the Data Protection Act from 1998 and the General Data Protection Regulation effective from May 2018.
We request, retrieves and processes only the data needed to carry out its core functions, such as delivering courses and workshops, communicating with interested parties or performing coaching sessions.
The purpose of this policy is to define internal procedures related to data gathering and handling in compliance with the GDPR principles. At Challenge U Change U Ltd, data is
- Collected according to lawful processing and transparency principles, and processed under one of the following bases.
- Consent: data is retrieved and processed after explicit consent from individuals and according to the needs of the information or services requested by them.
- Contract: data necessary to stablish a contract relationship with an individual.
- Legitimate interest: processing of data for the legitimate interest of Challenge U Change U Ltd or associated bodies. This can be overridden by the existence of a good reason to protect an individual’s data above legitimate interest.
- Limited strictly to what is needed for Challenge U Change U Ltd to carry out its core functions.
- Accurate and up-to-date. We put into place reasonable processes in order to keep data accuracy and relevance.
- Stored for a minimum of 2 years, depending on the information or service requested by the individual and delivered by Challenge U Change U Ltd. Individuals can request a copy of the data we keep, updates on their data or full deletion of their details from our archives.
- Shared only when required by law and to protect individuals’ rights, security or Challenge U Change U Ltd's rights. In such case, reasonable measures would be put in place according to GDPR principles.
Types of data collected
We collect the following types of data:
- Contact details for those interested in our services.
- Data related to client's identification and performance throughout the coaching process, as well as data required for administrative processes inside Challenge U Challenge U Ltd.
- Any other data provided voluntarily by individuals.
How data is used
Personal data is processed depending on the type of service requested.
- For clients, we collect data through registration forms, direct contact, sign ups and other digital platforms to support the coaching process.
- For general interest in services, data is collected via registration forms, via emails, on the web site or via interaction (email, phone, SMS, meetings etc) with Pauline Harley.
- Data may be used to generate aggregate analysis – courses preferences or web site visits, for example- which do not identify particular individuals.
- Individuals can request a copy of the data we keep, update their data or ask for full deletion of their details from our archives.
Access, storage and security
Data gathered and stored by Challenge U Change U Ltd can only be accessed by authorised staff and according to procedures that comply with GDPR regulation. In order to keep data secured, we take all necessary precautions, such as:
- Physical data is kept under secured and locked location in site and cannot be taken out of the premises unless it is absolutely necessary.
- Digital data access is password protected.
- Challenge U Change U Ltd does not share data with third or external parties.
- Procedures for appropriate discarding of physical and digital data are also in place.
We may contact individuals who have expressed interest in our services and have voluntarily given contact details, with information on our services.
Individuals can opt out at any time or withdraw consent.
In compliance with GDPR principles, at Challenge U Change U Ltd we recognise the rights of every individual regarding the personal data they share with us:
- The right to be informed in a clear and unambiguous way the data we retrieve and how it is processed.
- The right to access a full copy of the data we keep at a specific time, in a portable, readable and reusable format.
- The right to rectification; this means, to update or correct the data held by us.
- The right to request the full deletion of any type of personal data held by us.
- The right to restrict the processing of such data, as well as to object at any time the methods in which it is processed at any time.
Policy updates and regular reviews
This policy will be revised annually and updated as required.
19th July 2018