GDPR POLICY

PURPOSE

The purpose of this policy is to give you a clear explanation about how Thrive Your Life collect and process your personal information in the work we do. We may collect Personal Data whenever we have contact with you – through our website, emails, programmes and events.

We will use the information that we collect about you in accordance with:

  • The Data Protection Act 1998
  • The Privacy and Electronic Communications (EC Directive) Regulations 2003
  • The EU General Data Protection Regulation (Regulation EU 2016/679), (‘GDPR’) which becomes effective from 25 May 2018
WHO WE ARE

I am a fully qualified Thrive Programme Consultant with a Licence to deliver the Thrive Programme by The Thrive Programme (Thrive Holdings). I operate as Thrive Your Life and am regulated by the Association of Thrive Programme Consultants.

INFORMATION WE MAY COLLECT ABOUT YOU

Personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, i.e. anonymous data.

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

  • Identity Data includes first name, last name, title, date of birth, email and phone number.
  • Contact Data includes billing address, postal address, email address and telephone numbers.
  • Client Records – includes all information necessary for the establishment and performance of the services you have engaged us for. This includes notes of client meetings, coaching and training sessions, workshops, training, surveys, psychometric profiling and related assessments emails and communications both to and from you.
  • Usage Data includes information about how you use our website, products and services.

I may occasionally, where relevant collect a Special Category of Personal Data about you (this includes details 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, criminal convictions and offences).

You are under no statutory or contractual requirement or obligation to provide us with your personal data. However, if personal information is not provided it may mean we are unable to communicate with you to provide the most effective service for your specific needs or ongoing support and information about potential future services.

HOW WE COLLECT YOUR DATA

We collect and store only the information that is relevant to our work with you and our services. We collect this information in a number of ways:

  • When you contact us through our website, email or telephone
  • When you contact us through Social Media
  • When the recommendation has come from someone external to Thrive
  • When you purchase our products or services
  • When you attend one of our events
  • When we meet at a networking / business event

Information you give us

Any information you give us is stored in an appropriately secure way. The information is used only for the purpose it is intended for and is not passed onto any third parties without your express permission.

Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies and other similar technologies.

Information from third parties

We occasionally receive information about you from third parties as set out below:

  1. Analytics providers such as Google
  2. Advertising networks such as Facebook
  3. Search information providers such as Google Adwords
HOW WE MAY USE YOUR INFORMATION

We will only use your personal information as the law allows us to:

In pursuit of the delivery of a specifically requested service or product

For occasional Marketing Communication

We aim to communicate with you about the work that we do in ways that you find relevant, timely, respectful, and never excessive. To do this, we may use data that we have stored about you as well as any contact preferences you may have told us about.

We will give you an opportunity to opt out of or unsubscribe from of receiving electronic communications.  Alternatively, you can use the contact details at the end of this policy.

We sometimes use data for research and support purposes – unless client consent has been obtained, this data is anonymised before public release.

All clients providing video or written testimonials from 25th May 2018 will be asked to provide consent (which we will store) for the use of their testimonial. You can ask for its removal/erasure from our systems and public sites at any time.

DISCLOSURE OF YOUR DETAILS TO THIRD PARTIES

There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:

  • To our service providers who process data on our behalf and on our instructions (for example our Skype, website designers, social media experts). We require all third parties to respect the privacy of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
  • Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).
  • We do not sell personal details to third parties for any purpose.
  • Your personal data will be treated as strictly confidential and will be shared only with personnel directly contracted with Thrive and who are bound to a duty of confidentiality by legislation.

The Thrive Programme is not responsible for any personal data that individuals choose to share on public forums including review sites, social media including public Facebook support groups and Twitter chat sessions. We advise caution before posting sensitive or personally identifiable information (PII) relating to yourself or others on such sites

SECURITY OF YOUR PERSONAL INFORMATION

All personal data will be securely stored both electronically and manually. Electronic data is password protected and manual data e.g. paper records is kept in secure locked storage.

We will not transfer, process or store your data anywhere that is outside of the European Economic Area, unless we have a contractual agreement in place that is of an equivalent standard to GDPR. By submitting your data, you are agreeing to this. We will take all reasonable steps to ensure your data is treated securely and in accordance with this privacy policy.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We will carry out an electronic data review of all client records stored on an annual basis, deleting and/or destroying any records that are no longer relevant.

Our Insurance requires us to keep such documentation for a minimum period of 5 years.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal information, as follows:-

  1. a) Request access to your personal information

You have a right to request a copy of the personal information that we hold about you. Please use the contact details at the end of this policy if you would like to exercise this right, or any of the rights listed below.  If you are a European citizen and consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, i.e. the Information Commissioner’s Office.

  1. b) Request correction of your personal information

You have the right to request that we correct the personal information we hold about you, although we may need to verify the accuracy of the new information you provide to us.

  1. c) Request erasure of your personal information

You have the right to request that we delete or remove personal information where there is no good reason for us continuing to process it. Please note that we may not always be able to comply with your request for erasure if there are specific legal reasons- which will be notified to you at the time of your request.

  1. d) Object to processing of your personal information

You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  1. e) Request restriction of processing your personal information

You have the right to request that we suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  1. f) Request transfer of your personal information

You have the right to request that the personal information we hold about you is transferred to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  1. g) Right to withdraw consent

In circumstances where we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

For more details on your legal rights, please contact the Information Commission as follows https://ico.org.uk

NOTIFICATION OF CHANGES TO OUR PRIVACY POLICY

This privacy policy may change from time to time. Please visit this section of our website periodically in order to keep up to date with changes in our privacy policy.

CONTACT DETAILS AND FURTHER INFORMATION

Please get in touch with us if you have any questions about any aspect of this privacy policy, and in particular if you would like to object to any processing of your personal information that we carry out for our legitimate organisational interests.

Please also contact us if you have any questions about the information we hold about you, or to change your contact preferences with us:

Email: info@thriveyourlife.co.uk                                      Call us: +44 (0)7870 166 105