Privacy Policy
Who we are
Personal Best Limited
36 Cumberland Road
Ashford
Surrey
TW15 3DB
Data Protection Contact
We are not obliged by law to appoint a Data Protection Officer, but we have appointed one nonetheless:
James Daniel
james@personalbest.ltd.uk
If you have any queries, requests or complaints, please contact James in the first instance.
We are registered with the UK Information Commissioner's Office. If you are not able to resolve Data Protection or privacy matters satisfactorily with us, you can contact them.
We do not have a Data Protection representative in any other country.
Purposes of Personal Data Processing
Very often, someone other than you (usually the organisation you work for) will have arranged and/or paid for the workshop or coaching in which you take part: where this is the case, we call them your "sponsor". In what follows, any reference to "your sponsor" should be interpreted as applying only if you have one.
We collect and process personal data for the purpose of delivering our services. The minimum personal data we need to collect and process depends on the service:
Workshop with no follow-up
Workshop with email-only follow-up
Workshop with coaching follow-up
Coaching
We aim to minimise, to zero where possible, the personal data we require from you or your sponsor (if there is one).
The personal data we get from your sponsor depends on the arrangements we have agreed with your sponsor. We will get personal data from your sponsor where we can't avoid it, and get anything else we need from you. Beyond this basic minimum, it is up to you what personal data you disclose to us during the delivery of our service.
We collect and process personal data to enable us to maintain business relationships with our customers and suppliers. This is usually limited to business email addresses and any other electronic contact information sent to us in electronic correspondence.
Where we exchange electronic correspondence with you as follow-up support for coaching or a workshop, we will keep it indefinitely. Your coach may make notes relating to coaching sessions, and we will keep these notes indefinitely. Access to electronic correspondence and coaching notes is strictly need-to-know.
We collect and process personal data to enable us to respond to contact requests from our website. This is limited to the data requested by the "Contact Us" page of our website, and the contents of any subsequent electronic correspondence.
We don't use personal data for direct marketing. We don't do any direct marketing.
We don't use personal data for any kind of profiling, scoring, predictive analysis or automated decision-making.
Lawful Basis for Processing your Personal Data
The law (UK GDPR) says that we may only process your personal data if we have a lawful basis for doing so. There are six lawful bases, and we rely on three of them:
Where we have a contract with you to deliver our service, we process your data on the basis of Contractual Obligation. We couldn't make and fulfil our contract with you if we didn't gather the personal data we do and process it as we do.
Where we have a contract with your sponsor to deliver our service, we process your data on the basis of Legitimate Interest. We have a legitimate commercial interest in fulfilling our contract with the sponsor, and we collect and process only enough personal data about you to enable us to do that. We assume that you are participating voluntarily and that you expect to benefit. If this is not the case, please tell us.
Where data provided to us by a sponsor is to be deleted (for example, on termination of our contract with the sponsor) but we keep it, having first obtained your consent to do so, we then process your data on the basis of Explicit Consent. You may withdraw your consent at any time.
We also process website contact personal data and personal data we use for maintaining business relationships with our customers and suppliers on the basis of Legitimate Interest. We have a legitimate commercial interest in:
Responding to website contacts, which are either prospective clients enquiring or existing clients requesting support, and conducting subsequent conversations by email, phone and other electronic means
Conducting business with customers and suppliers by email, phone and other electronic means
Sources of Personal Data
We don't buy or harvest personal data.
Except for any personal data given to us by your sponsor, the personal data of yours which we keep and use will have been given to us by you, with your knowledge.
Transfers to third parties
We may pass your personal data to an associate, where we have asked that associate to deliver your workshop or coaching. We will give them only what they need, and they will use your data for the same purposes, in the same way, and with the same restrictions, that we would if we were providing that service directly.
We pass data to IT service providers for purposes such as sending, routing and storing emails, storing calendar and contact information on our behalf, and storing notes in electronic form. Legally, this counts as a data transfer from us to the service providers. Our service providers do nothing with this data other than storing it and allowing us to retrieve it again, except that they also send emails on our behalf.
We see our relationship with you as being like a doctor-patient relationship. We won't share any of your personal data with a sponsor or any other party which you have disclosed to us in the course of our providing the service, unless we know they already have it or we are legally obliged to. We won't disclose any assessments, evaluations, opinions or the like which we may have formed in the course of providing the service, whether or not these count as personal data.
Where we pass data to someone else for any of the purposes listed above, we ensure that they are bound by their local law or by their contract with us to treat your data so as to honour our legal duty to you.
We don't provide personal data to anyone else, other than as listed above.
Transfers of Personal Data between Countries
When we gather personal data, the master copy of it will be stored in the UK.
If we have acquired your personal data in the UK and are delivering our service to you in the UK, your personal data will not leave the UK.
We deliver services which can have an international dimension. A transfer of personal data between countries will occur if:
you are resident outside the UK when you give us any of your personal data. There will be a transfer of that data from the country you live in to the UK.
you are resident outside the UK when your sponsor gives us any of your personal data. There will be a transfer of that data into the UK. The source country will depend on where your sponsor sends it from.
we are delivering our service to you outside the UK and your coach or workshop leader needs access to your personal data while outside the UK to do this. There will be a transfer of the necessary data from the UK to the country where the coach or workshop leader delivers the service.
We transfer data only to fulfil a contractual obligation to you or your sponsor. The data will be removed from any non-UK country once the coach or workshop leader leaves that country.
How long we keep Personal Data
Personal data we gather in the course of responding to website contact requests is deleted once we are reasonably sure that the conversation is over, unless that person already is, or becomes, a client of ours.
Personal data we gather for maintaining business relationships with customers and suppliers is deleted on termination of the relevant relationship.
Personal data we gather in the course of delivering our service is deleted according to various criteria, as follows.
Personal data which was provided to us by your sponsor:
relating to physical addresses will be deleted once we have made any visits required to deliver the service
will be deleted on termination of our agreement with your sponsor, if that agreement requires us to. This will usually mean that you can't access lifetime support once we have deleted your data.
will otherwise be treated as if you had provided it to us
Personal data which was provided to us by you:
relating to physical addresses will be deleted once we have made any visits required to deliver the service, unless we have a contract with you, in which case we will keep any physical address data necessary to enforce our rights under the contract
will be deleted when you ask us to
will be deleted when we have finished delivering our service to you, if the service doesn't involve access to lifetime support
will be deleted when you let us know that you don't want any further support
Where we have an agreement with your sponsor which might require us to delete the personal data about you which your sponsor has provided to us, and that means you might lose access to lifetime support, we will tell you. If you provide us with separate consent to keep that data, we will do so, and you will then keep access to lifetime support for as long as you wish.
If our service to you includes lifetime support, we will, as a minimum, keep enough of your personal data to enable us to establish your entitlement to that support, and we will keep it indefinitely, unless you request us to delete it, or your sponsor requests us to delete it and you do not instruct us not to. What we keep will be limited to your name, a personal or business email address, any email correspondence between us, and in the case of coaching, any coaching notes.
Our contracts with our customers involve mutual obligations, such as non-disclosure of trade secrets, which do not terminate. We keep the name and address of any customer with whom we have made such a contract indefinitely, whether or not we are asked to delete it. In the case of a personal or small business customer this contact information may be personal data.
Your rights
You have the right to:
have access to a copy of the personal data we hold about you, so that you can check it
have us send you a copy of the personal data we hold about you, so that you can transfer it to someone else. In this case, we may delete (for example, from emails) any information which we consider to be unnecessary for your exercise of this right.
ask us to correct or update any of the personal data we hold about you which is incorrect or out of date. Note that in most cases, you are our only source of data about you. If your details change and you don't tell us, we won't know.
ask us to delete any part, or all, of the personal data we hold about you.
withdraw your consent for us to use your personal data for any purpose to which you may previously have consented. You don't have to give a reason.
Before we act on any of these things, we have to make sure that we know that the request comes from you, or from someone legitimately acting for you.
If you withdraw consent or ask us to delete data, this may affect our ability to deliver our services to you. Depending on the service and the timing of the deletion:
we may not be able to arrange for you to participate in a workshop or coaching session
we may not be able to verify that you are a past client of ours, and if we can't, you will not qualify for further lifetime support.
If you ask us to do something which would have either of these effects we will let you know before we carry out your instruction.
Appeals
If you have asked us to put something right and you continue to be unhappy with our response, you have the right to bring a complaint to the UK Information Commissioner's Office:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Fax: 01625 524510
https://ico.org.uk/about-the-ico/who-we-are/directions-head-office/
Exceptions
Statements above about what we will or won't do will not apply where:
We are, or reasonably believe we are, obliged to do otherwise by force of law, regulation or the like in any relevant jurisdiction. We will always seek to comply in a way which minimises the effect of the exception.
We have a relationship with you as a customer, and need to retain your contact details so that we can enforce our post-termination rights under our contract with you.
We have your (or, if not your, an authorised person's) express consent to do otherwise. We will only seek any such consent in exceptional circumstances, and when we do, we will make it clear what we are, and aren't, asking for.