MURDOCH HEALTH CONSULTING LIMITED
GDPR 2018 PRIVACY NOTICE
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
- Murdoch Health Consulting Limited is pleased to provide the following information:
- Who We Are
Murdoch Health Consulting Limited delivers coaching and health consultancy services. Coaching services are delivered in line with the Association for Coaching’s Global Code of Ethics for Coaches, Mentors and Supervisors.
- Personal Data
a)For the purposes of providing a coaching service, Murdoch Health Consulting Limited may require you to provide detailed personal information. We will only collect what is relevant and necessary for the service you have commissioned. Your coach will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your coaching, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement.
To be able to process your personal data it is a condition that you give your explicit consent to allow Murdoch Health Consulting Limited to document and process your personal data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your coaching.
Your data will never be actively shared, except where it is required by law, if clinical case notes are subpoenaed by court, or if life or safety are seriously threatened. As part of your coach’s duty of care, they may have to contact Emergency Services or your GP or pass this information on to the relevant authorities. Wherever possible, your coach would discuss this with you beforehand.
b)For marketing purposes, Murdoch Health Consulting Limited may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which the company believes may be of interest to you.
c)In making initial contact with Murdoch Health Consulting Limited you consent to Murdoch Health Consulting Limited maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. Murdoch Health Consulting Limited do not broker your data and you can ask to be removed from our marketing database by emailing or phoning the company using the contact details provided at the end of this Privacy Notice.
d)Some basic personal data may be collected about you from marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
e)Murdoch Health Consulting Limited will only collect the information needed so that we can provide you with the services you require; the business does not sell or broker your data.
- Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit consent and legitimate interest to respond to enquiries concerning the services provided.
- Legitimate interests pursued by Murdoch Health Consulting Limited
To promote coaching and consultancy services.
Through agreeing to this privacy notice you are consenting to Murdoch Health Consulting Limited processing your personal data for the purposes outlined. You can withdraw consent at any time by using the email address or telephone number provided at the end of this Privacy Notice.
Murdoch Health Consulting Limited will keep your personal information safe and secure, only staff engaged in providing your coaching will have access to your records. However, depending on the site at which your coaching takes place, there may be on-site administrative staff who have access to your notes to update contact information and add other administrative data. Our administration team will have access to your contact details so that they can make appointments and manage your account. Murdoch Health Consulting Limited will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The company may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
- Retention Policy
At your first coaching session you will receive a copy of a Privacy Statement which explains how your data is handled in order to provide your coaching service.
You will be asked to sign this statement giving your explicit consent to the creation and storage of records relating to the coaching service you receive.
- Your identifiable data captured on this form will be stored in a locked filing cabinet and destroyed by shredding, one month after your coaching has ended.
- If your preferred method of contact is by phone or text, your number will be stored in a password protected mobile phone using your first name and last name initial and deleted one month after coaching has ended.
- Your email address and any email correspondence will be deleted one month after coaching has ended.
- Anonymised session notes will be stored in a locked filing cabinet for a period of up to 7 years and shredded after this time period.
- The coach receives regular supervision where they can discuss anonymised session notes to support the coaching process.
Your right to withdraw consent
- A printed copy of the Privacy Statement will be made available to you before any coaching work can commence and once signed you have a right to access this information and withdraw consent to Murdoch Health Consulting Ltd collecting and storing your personal data.
- Data Storage
All Data is held in the United Kingdom. Murdoch Health Consulting Limited does not store personal data outside the EEA.
- Your rights as a data subject
At any point whilst Murdoch Health Consulting Limited is in possession of, or processing your personal data, all data subjects have the following rights:
Right of access — you have the right to request a copy of the information that we hold about you.
• Right of rectification — you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten — in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing — where certain conditions apply you have a right to restrict the processing.
• Right of portability —you have the right to have the data we hold about you transferred to another organisation.
• Right to object — you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling — you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Murdoch Health Consulting Limited refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request Murdoch Health Consulting Limited can confirm what information it holds about you and how it is processed.
- You can request the following information:
Identity and the contact details of the person or organisation (Murdoch Health Consulting Limited) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Murdoch Health Consulting Limited and information about these interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erasure, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn't collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
- To access what personal data is held, identification will be required
Murdoch Health Consulting Limited will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required.
In the event that you wish to make a complaint about how your personal data is being processed by Murdoch Health Consulting Limited you have the right to complain to us. If you do not get a response within 30 days, you can complain to the Information Commissioner’s Office (ICO).
The details for each of these contacts are:
Murdoch Health Consulting Limited:
Mandy Murdoch (Company Director)
Telephone: +44 (0) 7792 483 436
Information Commissioner’s Office (ICO):
Address: Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone: +44 (0) 303 123 1113