Leading Figures is a coaching and consulting firm offering executive, leadership and team coaching to the finance and professional services sectors.
Leading Figures collects and processes personal data relating to its clients and coachees as part of the services we provide to clients. Leading Figures is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
WHAT INFORMATION DOES LEADING FIGURES COLLECT?
Leading Figures collects and processes a range of information containing personal data about you. This may include the following:
- Your name, address and contact details, including email address and telephone number;
- Details about your career, working relationships and professional aspirations;
- Financial information (where you are purchasing services from us); and
- In some cases, we may process special category data (more sensitive personal information) about you, for example, health data. We will only collect special category data where this information has been volunteered by you.
We collect this data to communicate with our clients and coachees when working together, to provide the services we are engaged to provide and to highlight any specific events our clients, coachees and contacts may find of interest to attend. Additional personal information is collected during the natural course of our coaching sessions with our clients and coachees, mostly by way of the confidential conversations we have with clients and coachees but also in some circumstances by completion of a questionnaire.
Leading Figures may collect information in a variety of ways including directly from you or from third parties. Individual and collective psychometric and 360 data can be collected by Leading Figures through our sub-contractors. Clients and coachees are made aware of this if they provide information to such third parties.
We collect data from our clients and coachees directly during conversations and meetings, where we may record, mostly in written form, key issues raised by the clients and coachees that can relate to any aspect of their life, activities, feelings and beliefs. We may take notes of such points to help us assist our clients and coachees in their personal and professional development. We also collect personal data through psychometrics and leadership assessments. Where we process special category data, we will only do so where the individual who has provided their personal data has provided explicit consent for us to do so and they believe it will be of benefit to them for their future development.
WHY DOES LEADING FIGURES PROCESS YOUR PERSONAL DATA?
The data is used as part of the coaching services we provide to our clients and coachees. While we will have a contract in place with our clients which enables us to process client personal data, we may not have a contract in place with those individuals (coachees) who provide their personal data. Where this is the case, we have a legitimate interest to process the personal data of our coachees. Where we process special category data, we will only do so on the basis of consent.
Leading Figures also collects personal data to allow it to communicate with clients and coachees and highlight any specific events they and our contacts may find of interest to attend. Additional personal information is also collected during the natural course of our coaching sessions with our clients and coachees, mostly by way of the confidential conversations we have with clients and coachees, but also in some circumstances by completion of a questionnaire. As agreed with the client and coachees, individual and collective psychometric and 360 data can be collected by Leading Figures through their subcontractors. Clients and coachees are made aware of this if they provide information to such third parties. We have a legitimate interest to process personal data in these ways to provide the services we are engaged to provide, to provide better customer services and to advise you of events in which you may be interested.
Where we process personal data on the legal basis of legitimate interests we adopt the Information Commissioner’s three-part test in terms of:
- Purpose – that there is a legitimate interest behind the processing.
- Necessity – that the processing is necessary for that purpose.
- Balancing – that our legitimate interest is not overridden by the individual’s interests, rights or freedoms.
The nature of the service we provide is often one of a private confidant where coachees will reveal personal information to us that they feel is helpful to explore as part of their personal and professional development. We do not share any personal details or data points with other third parties unless we have the explicit permission of our clients and coachees to do so.
Where we seek your consent to process special category personal data (for example, where we process health or other sensitive information about you) we will provide full details of what we are seeking consent for, so that you will be able to carefully consider whether to provide that consent. Where you have provided consent, you have the right to withdraw that consent at any time.
WHO HAS ACCESS TO DATA?
Your information may be shared internally as appropriate but strictly limited only to those who require access to that personal data. We will also share your data as required by law and with our professional advisers.
Leading Figures may also share your data with third parties, including subcontractors engaged by Leading Figures to provide services on behalf of Leading Figures. Where we do so, we will have appropriate contractual arrangements in place to ensure the security and confidentiality of your data. Leading Figures does not share your data with other companies or organisations to enable them to send their own marketing communications to you.
If your personal data is transferred outwith the EU we will ensure that adequate safeguards are in place, an adequacy agreement or other contractual arrangement is in place as required by law.
HOW DOES LEADING FIGURES PROTECT DATA?
Leading Figures takes the security of your data seriously. Leading Figures has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its partners or associates in the performance of their duties.
Where Leading Figures engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data. They are also not allowed to use your personal data for their own purposes.
All electronic data is held on password-protected devices with appropriate firewalls in place.
Leading Figures’ email communications and documentation systems are served by the Microsoft Office 365 Business Premium platform.
The partners and associates treat paper data in the same way as electronic data as outlined above. All data processors are required to have adequate filing systems in place with lockable cabinets.
Your personal data will be retained in hard copy in files which are stored in either a locked cabinet or within Leading Figures’ IT system with password protection.
HOW LONG DOES LEADING FIGURES KEEP YOUR DATA?
Leading Figures will hold your personal data for no longer than is necessary for the purposes for which it is being processed. Leading Figures will generally retain personal data for the period during which we provide services to a client or coachee and for a further period of 7 years after last contact with the client or coachee.
Electronic data is deleted while hard copy information is security shredded either by us or a reputable company that provides certified destruction.
In line with the ICO guidelines our clients and coachees (or any individual we hold information on) can exercise their right to ‘subject access’ of the personal data we hold on them. Such requests can be made verbally or in writing to which we will respond within one month.
As a data subject, you have a number of rights in relation to your personal data. These include the right to:
- Access and to obtain a copy of the data Leading Figures is processing on request;
- Require Leading Figures to change incorrect or incomplete data;
- Require Leading Figures to erase or stop processing your data, in certain circumstances;
- Object to the processing of your data where Leading Figures is relying on its legitimate interests as the legal ground for processing;
- Portability; and
- Object to automated decision making.
If you would like to exercise any of these rights, or if you have any concerns about how your personal data is being processed please contact Leading Figures via one of the following options:
Call: 020 3951 0121
If you believe that Leading Figures has not complied with your data protection rights, you can complain to the Information Commissioner. Contact details are available at www.ico.org.uk
WHAT IF YOU DO NOT PROVIDE PERSONAL DATA?
Where you have entered into a contract with Leading Figures for provision of goods or services, failing to provide the data may mean that Leading Figures is unable to properly implement the contract and that you are unable to exercise certain contractual rights.
MONITORING AND REVIEW
This policy was last updated in March 2020 and shall be regularly monitored and reviewed, at least every two years.