I, Atul Nayak PhD, 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 all of my clients/ coachees 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.
1. Information About Me
Atul Nayak PhD (DTR Coach & Innovation Consultant) and Sole Proprietor. Correspondence address: International House, 12 Constance Street, London, E16 2DQ.
I am a member of European Mentoring and Coaching Council (EMCC) with current membership No. M95648ID. The current website is accessible as www.emccouncil.org.
2. What Does This Notice 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.
3. 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.
The personal data that I use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which I will always work to uphold:
a) The right to be informed about my collection and use of your personal data. This Privacy Notice 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 11.
b) The right to access the personal data I hold about you. Part 10 will tell you how to do this.
c) 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 11 to find out more.
d) 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 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to me using your personal data for a particular purpose or purposes.
g) 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.
h) 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.
i) Rights relating to automated decision-making and profiling. I do not use your personal data in this way.
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 11. 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 11.
5. What Personal Data Do You Collect and How?
Depending upon your use of My work, survey or questionnaire, I may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. I do not collect any personal data relating to children and data relating to criminal convictions and/or offences.
Data Collected How I Collect the Data
Identity Information including name, gender, date of birth range or category, occupation, career, health, character profile. Responses to questions or questionnaire during coaching interview or innovation consultancy are logged securely on file and password protected. Contact information including email address, telephone number, town/city, post code. Responses to contact information logged securely on file and password protected. Business information including business name, occupation, length of employment.
Same as above.
Payment information including card details, bank account for direct debit or cash transaction.
Same as above. Reliable third party merchant service with security protocols is chosen. All data is recorded securely. Profile information including customer database, CRM. All customer profile and CRM data securely recorded and retained on file. Data from third parties including merchant services. Reliable third party merchant services with security protocol used.
6. 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 may use your personal data, and my lawful bases for doing so:
What I Do What Data I Use My Lawful Basis
Administering my business.
Coachee/ Client demographics, contact information.
To know and keep in touch with my Coachee/Client.
Supplying my services to you.
Life balance questionnaire, Innovation Questionnaire and related materials, DTR Coaching and Innovation guidance.
Managing payments for my services.
Record of payment by individual coachees (yes/no).
To know who has paid or not paid.
Personalising and tailoring my services for you.
Coachee review, Coach Services feedback form, Complaints.
Measure of successes and essential improvements.
Communicating with you.
Email, third party business platform, telephone.
As absolutely necessary in running a successful business.
Supplying you with information by email or post that you have opted-in-to (you may opt-out at any time by email or unsubscribe feature.
Respective business may keep me informed about information I may have not come across.
Up to date with current information that supports my private research and promotes further intellectual discussions. With your permission and where permitted by law, I may also use your personal data for marketing purposes, which may include contacting you by email or telephone or post with information, news, and offers on my 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 11.
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.
7. How Long Will You Keep My 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 Duration of Storage
Identity Information including name, gender, date of birth range or category, occupation, career, health, character profile.
Names of individual coachees are kept for 10 years or maybe longer for professional relations. The rest of the data stated is kept lifelong for R&D.
Contact information including email address, telephone number, town/city, post code.
Email address and telephone no. updated and kept for 20 years or maybe longer for professional relations. Other data kept lifelong for R&D.
Business or employment information including business name, occupation, length of employment.
Individuals names kept for upto 20 years or maybe longer for professional relations. Other data kept lifelong for R&D.
Payment information including card details, bank account for direct debit or cash transaction.
Secure card payment details never kept by me. Other payment details relating to direct debit immediately destroyed after payment received. Individual’s payment name kept for upto 1 year as payment record.
Profile information including customer database and CRM.
Individuals names kept for upto 20 years or longer for professionals relations.
8. 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 or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell me everything I need to know to respond to your request as quickly as possible. 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 twenty days and, in any case, not more than 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.
11. 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 details (for the attention of Atul Nayak PhD):
Mobile number: 07851085854.
Postal Address: International House, 12 Constance Street, London, E16 2DQ.
9. Changes to this Privacy Notice
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 made available directly to you via email and post. This Privacy Notice was last updated on 16/01/2020.