Life In Action respects your privacy and is committed to protecting your personal data.
It also tells you about your privacy rights and how the law protects you.
- Our website and the Company Life In Action Ltd.
Our website at www.lifeinaction.co.uk does not sell goods but offers information on the services we offer in relation to Counselling and Psychotherapy and Coaching. We also provide information on HR consultancy services. This website is not intended for children and we do not knowingly collect data relating to children.
- Personal data which we collect 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).
When we agree to work together a file is set up for you and you are given a client code that you are not identifiable from. Any written information you provide to us is stored with your file and is kept locked and only accessible by your therapist or consultant. Any notes taken during our work with you are what we deem “reflective” notes and are owned by the therapist working with you. These are covered by separate rules and are in line with the ethical framework we abide to.
We collect a variety of information about our clients (you!) and visitors to the life In Action website. This personal data falls into two categories
Identity Data includes title, first name, last name, username or similar If you interact with us through social media, this may include your social media user name.
Contact Data includes address, email address and telephone numbers.
Usage Data includes information about how you use our website and services.
Tracking Data includes information we or others collect about you from cookies and similar tracking technologies.
Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
We do not collect any Special Categories 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). Nor do we collect any information about criminal convictions and offences.
Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.
- How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact details by filling in forms or by corresponding with us by post, phone, email or through social media.
This includes personal data you provide when you:
- sign up to receive the news letter
- make enquiries or request information be sent to you;
- ask for marketing to be sent to you;
- engage with us on social media or our Blog;
- leave comments or reviews on our services such as Google Business (please be kind!).
Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:
- Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;
- Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- How we use your personal data
- Where we need to perform the contract, we are about to enter into or have entered into with you. For example, when you purchase coaching credits products, that’s a contract.
- Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.
See Explaining the legal bases we rely on to process personal data to find out more about the types of lawful basis that we will rely on to process your personal data.
6. Explaining the legal bases we rely on to process personal data
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
We do not carry out any automated decision making.
If you ever have any questions about this, all you have to do is ask. See How to contact Life In Action about privacy below.
7. Advertising, marketing and your communications preferences
We do not carry out direct marketing by email, phone, text or post.
If you do sign up to our newsletter you have a right at any time to change your mind and say no thank you and opt out (but we’d be really sorry to see you go, so please gives us a chance by fine tuning your preferences before really leaving us!). The easiest way to opt out is to drop us an email and we will remove you from our list.
- Disclosures of your personal data
We do not share your personal data with any third party. Your data is kept by us and will only be used by us. This includes your contact details and any notes you have sent to us using the contact us form on this website.
9. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to the consultant therapist working with you. They will not share your personal data.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. Third-party links
11. Data retention
We will only keep 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.
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.
By law we have to keep basic information about our customers (including Contact, Identity and any case notes collected by us during our work with you) for six years after they stop being customers for tax purposes.
We also make a promise to you that you can come back at any time in the future and as such records are kept for a period of 6 years. After which they are destroyed.
In some circumstances you can ask us to delete your data; see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
12. Your legal rights
If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:
- The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you;
- The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
- The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
- The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
- The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
- The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
- Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.
These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK information commissioner’s office website.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
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.
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
13. How to contact Life In Action about privacy
Life In Action Limited 2018