Think with Jude understands that your privacy is important to you and that you care about how your personal data is used. I respect and value the privacy of everyone who visits this website, https://www.thinkwithjude.com (“MySite”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with my obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested as a condition of using this site and/or working with me.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Cookie”: means a small text file placed on your computer or device by My Site when you visit certain parts of My Site and/or when you use certain features of My Site. Details of the Cookies used by My Site are set out in Part 14, below
“Cookie Law”: means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
“Organisation”: means the organisation the work is being done for, Think with Jude may not have a contract with the organisation as I may be carrying out work as an associate of another company
“Associated Company”: means an organisation that has contracted with Think with Jude to provide services to an organisation on their behalf
“Coachee”: means the person receiving the coaching
2. Information About Me
My Site is owned and operated by Think with Jude, a sole trader.
Data Protection Officer: Jude Sclater.
Email address: [email protected].
I am a member of the European Mentoring and Coaching Council and the Association for Coaching and I comply with the Global Code of Ethics.
3. What Does This Policy Cover?
This Privacy Information explains how I use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
My Site may contain links to other websites. Please note that I have no control over how your data is collected, stored, or used by other websites and advise you to check the privacy policies of any such websites before providing any data to them.
4. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are Your Rights?
Under the Data Protection Legislation, you have the following rights, which I will always work to uphold:
The right to be informed about my collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact me to find out more or to ask any questions using the details in Part 15.
The right to access the personal data I hold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by me is inaccurate or incomplete. Please contact me using the details in Part 15 to find out more.
The right to be forgotten, i.e. the right to ask me to delete or otherwise dispose of any of your personal data that I hold. Please contact me using the details in Part 15 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to me using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if I am relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to me directly, I am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask me for a copy of that personal data to re-use with another service or business in many cases.
For more information about my use of your personal data or exercising your rights as outlined above, please contact me using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data I hold about you changes, please keep me informed as long as I have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about my use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. I would welcome the opportunity to resolve your concerns myself, however, so please contact me first, using the details in Part 15.
6. What Data Do I Collect and How?
Depending upon your use of My Site and the methods you have used to get in contact with me, I may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about my use of Cookies. I do not collect any ‘special category’ or ‘sensitive’ personal dataorpersonal data relating to children or data relating to criminal convictions and/or offences.
Data Collected | How I Collect the Data |
Identity Information including First Name, Last Name | Verbally, email, text, message, Mailchimp, website form from the client, their organisation or the associate company their organisation has contracted to fulfil the contract. |
Contact information including email address, phone number. | Verbally, email, text, message, Mailchimp, website form from the client, their organisation or the associate company their organisation has contracted to fulfil the contract. |
Business information including organisation name, job title/role/grade, department, billing address, office location | Verbally, email, text, message, website form from the client, their organisation or the associate company their organisation has contracted to fulfil the contract. |
Payment information including payment date, payment amount. | From my bank from bank statements. |
Profile information including marketing and communication preferences, survey data, feedback and testimonial data. | Verbally, email, text, message, mailchimp, website form from the client, their organisation or the associate company their organisation has contracted to fulfil the contract.. |
Technical information including website use, IP address, browser, operating system, length of page visit, page views, navigation paths, frequency of use, dates and times you access emails distributed by Mailchimp, timezone settings, geographical data, metrics on deliverability of emails and other electronic communications through Mailchimp’s service. | From my site’s web host (Microsoft Excchange), website platform (WordPress) Google Analytics and Mailchimp These entities are based in the US and by using My Site you are consenting to your data being processed outside of the EU. All these companies operate in the EU and have privacy policies to comply with GDPR. |
Data from third parties including psychometric data. | Electronically or in paper directly from the organisation, associate company, coachee or psychometric provider. Psychometric reports will not be sent via email without the permission of the person the report is for. |
Coaching information including coaching notes, coaching session date, coaching session time, coaching session duration, coaching session location | Verbally, email, text, message, website form from the client. |
Comments left on My Site | When visitors leave comments on My site I collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment. |
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, I must always have a lawful basis for using personal data. The following table describes how I will use your personal data, and my lawful bases for doing so:
What I Do | What Data I Use | My Lawful Basis |
Respond to enquiries |
| Entering into or performance of contract |
Supplying my products and/or services to you |
| Entering into or performance of contract |
Communicating with you to perform the contract or sell more products and/or services |
| Consent |
Administering My Site |
| Legitimate interest to grow the business as My Site is my main marketing tool. |
Managing payments for my products and/or services |
| Entering into or performance of contract. |
Ongoing professional accreditations |
| Consent |
With your permission and/or where permitted by law, I may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on my products and/or services. You will not be sent any unlawful marketing or spam. I will always work to fully protect your rights and comply with my obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. I will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
I will only use your personal data for the purpose(s) for which it was originally collected unless I reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If I do use your personal data in this way and you wish me to explain how the new purpose is compatible with the original, please contact me using the details in Part 15.
If I need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, I will inform you and explain the legal basis which allows me to do so.
In some circumstances, where permitted or required by law, I may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will I Keep Your Personal Data?
I will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
Type of Data | How Long I Keep It |
Identity Information including First Name, Last Name | Coaching clients will have their data retained for two years and after this it will be anonymised so it can be submitted as part of future accreditation applications. Coaching Sponsor data is deleted annually for all past clients. Participant data is deleted/destroyed as soon as the contract is completed. For all others that get in contact your data will be retained until you ask for it to be deleted. |
Contact information including email address, phone number. | Coaching clients will have their data retained for two years and after this it will be anonymised so it can be submitted as part of future accreditation applications. Coaching Sponsor data is deleted annually for all past clients. Participant data is deleted/destroyed as soon as the contract is completed. For all others that get in contact your data will be retained until you ask for it to be deleted. |
Business information including organisation name, job title/role/grade, department, billing address, office location | Coaching clients will have their data retained for two years and after this it will be anonymised so it can be submitted as part of future accreditation applications. Coaching Sponsor data is deleted annually for all past clients. Participant data is deleted/destroyed within three months of contract completion. For all others that get in contact your data will be retained until you ask for it to be deleted. |
Payment information including payment date, payment amount. | This will be retained for six years as per HRMC guidance. |
Profile information including marketing and communication preferences, survey data, feedback and testimonial data. | Lists will be reviewed annually and anyone who has not interacted with marketing and communications will be asked if they would like to be removed from the list. Survey and Feedback data is kept in an anonymised form indefinitely to help me continue developing the business. |
Technical information including website use, IP address, browser, operating system, length of page visit, page views, navigation paths, frequency of use, dates and times you access emails distributed by Mailchimp, timezone settings, geographical data, metrics on deliverability of emails and other electronic communications through Mailchimp’s service. | Identifiable information is kept for 3 years and aggregate non identifiable information is kept indefinitely. |
Data from third parties including psychometric data | This is deleted/destroyed within three months of contract completion. |
Coaching information including coaching notes, coaching session date, coaching session time, coaching session duration, coaching session location. | This is deleted/destroyed within three months of contract completion, except coaching date and duration which is kept for ongoing accreditation requirements. |
Comments on My Site | If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue. |
9. How and Where Do You Store or Transfer My Personal Data?
I may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that I will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
I share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. I will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.
Please contact me using the details below in Part 15 for further information about the particular data protection mechanism me when transferring your personal data to a third country.
The security of your personal data is essential to me, and to protect your data, I take a number of important measures, including the following:
limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where I am legally required to do so;
All hard copy data is stored in a locked cabinet
All soft copy data is password protected using unique strong passwords.
10. Do I Share Your Personal Data?
I will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
In some limited circumstances, I may be legally required to share certain personal data, which might include yours, if I am involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
I sometimes use the following third parties to manage the provision of goods and services to you:
Recipient | Activity Carried Out | Sector | Location |
First Direct | Processing payments | Banking | United Kingdom |
Braywood LLP | Tax return preparation | Accounting | United Kingdom |
Forms (contact, survey, feedback), website analytics | Communications | United States of America | |
WordPress | Provision of Website structure may collect data about usage | Web technology | United States of America |
Hello Sign | Electronic signature of contracts and consent forms | Technology | United States of America |
Microsoft | Email, calendar, contact list, website Hosting, may collect usage data | Communications Web Hosting | United States of America |
MailChimp | Newsletter communication service, may collect usage and interaction statistics | Communication Service | United States of America |
If any of your personal data is shared with a third party, as described above, I will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, my obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, I will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.
11. How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via My Site, you may be given options to restrict my use of your personal data. In particular, I aim to give you strong controls on my use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from me which you may do by unsubscribing using the links provided in my emails.
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access My Site without providing any personal data at all. However, to use all features and functions available on My Site you may be required to submit or allow for the collection of certain data.You may restrict my use of Cookies. For more information, see Part 14.
13. How Can I Access My Personal Data?
If you want to know what personal data I have about you, you can ask me for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover my administrative costs in responding.
I will respond to your subject access request within one month and, in any case, not one month of receiving it. Normally, I aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date I receive your request. You will be kept fully informed of my progress.
14. How Do I Use Cookies?
If you leave a comment on My Site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
All Cookies used by and on My Site are used in accordance with current Cookie Law.
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
If you interact with a newsletter or other communication I send to you though Mailchimp a web beacon will be used to track certain behaviour such as whether the email sent through the Mailchimp platform was delivered and opened and whether links within the email were clicked. They also allow Mailchimp to collect information such as your IP address, browser, email client type, and other similar details. They use this information to measure the performance of my email campaigns, and to provide analytics information and enhance the effectiveness of their Services.
In addition to the controls that I provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?
To contact me about anything to do with your personal data and data protection, including to make a subject access request, please use the following:
Email address: [email protected]
Telephone number: 07769704837
16. Changes to this Privacy Policy
I may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if I change my business in a way that affects personal data protection.
Any changes will be immediately posted on My Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of My Site following the alterations. I recommend that you check this page regularly to keep up-to-date. This Privacy Policy was reviewed on 7 April 2020, no updates were made from when it was published on 11 June 2019.