Privacy policy
missing elephant limited is committed to maintaining the trust and confidence of those we engage and work with. This policy describes the information we collect; how we ensure the privacy and security of your personal information; how your data is handled, shared and stored, your rights over any personal information we hold about you as well as how to make a complaint.
If you have questions about the policy or other questions about your data, please contact me at brendan.barnes@missingelephant.com
1. How we use your information
missing elephant limited does not sell personal information.
We may use your personal information:
− to inform you about our services and respond to your questions,
− to deliver agreed services to you,
− to assess our business performance and to improve our services,
− for internal accounting, legal and regulatory purposes.
2. Personal information we collect
Information provided through correspondence with us by phone, email or letter may include administrative data: your titles and name; addresses; telephone numbers and details of the reason for your enquiry.
Should we contract with you the kind of personal information we hold will depend on the nature of the work we have been asked to do. For example, information relevant to a coaching or counselling conversation may include physiological, psychological, behavioural historical or cultural data. The data may be held in written or digital form.
3. Legal Bases
Data Protection legislation requires that we have a lawful basis for processing data. The bases used by missing elephant limited are as follows.
Performance of a contract
If we are engaged in a piece of work with you or we are in the process of contracting with you, we will hold your details in order to provide these services and will only use those details to provide the service you have requested.
Legitimate interest
To ensure the quality of the services we provide, client details may be shared in an anonymous form with missing elephant limited staff's professional supervisors and to evaluate our performance as a business and improve our services.
Consent
When contacting missing elephant by the above means, you may be invited to join our mailing list in order that we can contact you about coaching services, supervision, occupational therapy and any workshops and events that may be of interest to you. You can withdraw your consent at any time by mailing brendan.barnes@missisingelephant.com
The GDPR also makes sure that we look after any sensitive personal information that you may disclose appropriately. This type of information is called “special category personal information”. In the case of counselling, the lawful basis for processing any special categories of personal information is that it is for provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract between missing elephant limited and you). In the case of coaching and supervision it is consent.
4. Data Retention
If you contact us via email or phone to enquire about our services, we will use your information to respond to your enquiry. If the enquiry does not lead to a contract between us, we will hold your name, email and phone number on our database for a period of 12 months from the date of enquiry, after which it will be deleted.
If we work with you, the records of our contact with you will be retained during the contract period. Further retention will be based on guidance received from the relevant professional bodies and regulatory authorities. Our retention policy is available on request.
We may retain some records permanently if we are legally required to do so or for an extended period of time. For example, it is current best practice to keep financial records for a minimum of 7 years.
5. Disclosure of information
missing elephant does not share your data with third parties without your consent unless required by law to do so. If you suspect any misuse, loss or unauthorised use of personal data, please contact missing elephant brendan.barnes@missisingelephant.com
6. Cookies
We do not use traffic log cookies to identify which pages of our website are being used.
7. How we secure your information
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, all customer data is kept in secure locations either in a physical locked location or on a password-protected computer. Back-up storage is through Microsoft 365 and Dropbox. Should any computers be lost or stolen all efforts will be made to keep data secure. When working online, we make use of Zoom and Microsoft Teams, with Facetime and Whatsapp as backups.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
Should a data breach occur, we will inform the ICO and follow their recommendations to inform any affected clients.
8. Your rights
Under the relevant legislation, your rights include: the right to be informed about the data we hold about you; the right of access to the data we hold about you; the right to rectification of that data; the right to erasure of the data; the right to restrict processing of the data; the right to data portability and the right to object to the processing of your data. For more information about these rights see click here
Contact us or file a complaint
If you would like to exercise these rights, please contact missing elephant limited at brendan.barnes@missisingelephant.com
Please note that Missing Elephant Limited will require verification of identity before acting on any such request.
If you are not happy with how we have managed your personal information you can lodge a complaint directly to the Information Commission Officer (ICO) at ico.org.uk/global/contact-us
9. Data protection law
For the purpose of the General Data Protection Regulations 2018 missing elephant limited is a company registered in England and Wales under company number 09190538. We are registered with the Information Commissioner's Office.