Privacy Policy for Famn Ltd (referred to as “Famn”)
Last updated: 17th October 2023
About this document
Famn is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your engagement with us, in accordance with applicable data protection law including, but not limited to, the UK General Data Protection Regulation (“GDPR”) and Data Protection Act 2018. It applies to all coaching services Famn provides.
The Company is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
It is important to read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about coachees, so that you are aware of how and why we are using such information. We may amend this notice at any time.
Data protection principles
We will comply with data protection law. This says that the personal information we hold must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
The kind of information we hold about you
Personal data, or 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 (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection. These are data about ethnic origin, political opinions, religious or similar beliefs, trade union membership, health, sex life, criminal proceedings or convictions, genetic or biometric data.
We will collect, store, and use the following categories of personal information about you:
· Personal information details such as name, title and occupation.
· Professional contact details such as telephone numbers and business email addresses.
How is your personal information collected?
We collect personal information about those participating in coaching services either directly from coachees themselves or from client stakeholders/program sponsors to deliver contracted work.
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the agreed work, we have entered into with you.
2. Where we need to comply with a legal obligation.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Consent
By engaging in agreed work with Famn you consent to Famn collecting and storing personal data as required to deliver services. You have the right to request access and changes to personal data stored and withdraw consent for storage, this however may impact Famn's ability to deliver services.
Data sharing
We do not share any participant personal data collected with third party providers.
Transferring information outside the UK
The personal data that we collect from you may be stored on a mix of the Company’s and various cloud providers’ platforms and may be transferred to, and stored outside, of the UK. Where we do so we will always ensure it is in compliance with any relevant data protection laws.
Security
We have appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Rights of access, correction, erasure, and restriction
It is important that the personal information we hold about coachees is accurate and current. Please keep us informed if your personal information changes during your engagement in our services.
Under certain circumstances, by law you have the right to:
· Request access to your personal information (commonly known as a “data subject access request”).
· Request correction of the personal information that we hold about you.
· Request erasure of your personal information.
· Object to processing of your personal information.
· Request the restriction of processing of your personal information.
· Request the transfer of your personal information to another party.
Contact
For further information about your rights, or if you have any questions about this privacy notice or how we handle your personal information, please contact Alex Kyriacou, on alex@famn.co.uk. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Last updated: 17th October 2023
About this document
Famn is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your engagement with us, in accordance with applicable data protection law including, but not limited to, the UK General Data Protection Regulation (“GDPR”) and Data Protection Act 2018. It applies to all coaching services Famn provides.
The Company is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
It is important to read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about coachees, so that you are aware of how and why we are using such information. We may amend this notice at any time.
Data protection principles
We will comply with data protection law. This says that the personal information we hold must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
The kind of information we hold about you
Personal data, or 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 (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection. These are data about ethnic origin, political opinions, religious or similar beliefs, trade union membership, health, sex life, criminal proceedings or convictions, genetic or biometric data.
We will collect, store, and use the following categories of personal information about you:
· Personal information details such as name, title and occupation.
· Professional contact details such as telephone numbers and business email addresses.
How is your personal information collected?
We collect personal information about those participating in coaching services either directly from coachees themselves or from client stakeholders/program sponsors to deliver contracted work.
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the agreed work, we have entered into with you.
2. Where we need to comply with a legal obligation.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Consent
By engaging in agreed work with Famn you consent to Famn collecting and storing personal data as required to deliver services. You have the right to request access and changes to personal data stored and withdraw consent for storage, this however may impact Famn's ability to deliver services.
Data sharing
We do not share any participant personal data collected with third party providers.
Transferring information outside the UK
The personal data that we collect from you may be stored on a mix of the Company’s and various cloud providers’ platforms and may be transferred to, and stored outside, of the UK. Where we do so we will always ensure it is in compliance with any relevant data protection laws.
Security
We have appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Rights of access, correction, erasure, and restriction
It is important that the personal information we hold about coachees is accurate and current. Please keep us informed if your personal information changes during your engagement in our services.
Under certain circumstances, by law you have the right to:
· Request access to your personal information (commonly known as a “data subject access request”).
· Request correction of the personal information that we hold about you.
· Request erasure of your personal information.
· Object to processing of your personal information.
· Request the restriction of processing of your personal information.
· Request the transfer of your personal information to another party.
Contact
For further information about your rights, or if you have any questions about this privacy notice or how we handle your personal information, please contact Alex Kyriacou, on alex@famn.co.uk. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.