“The Client” — The individual attending a coaching session within “The Business”.
“The Business” — The employer providing Sanctus Coaching as a benefit to it’s employees (“Clients”)
“The Sanctus Coach” — The Coach providing Coaching Services via Sanctus.
“Sanctus” — the organization in relationship with The Business to provide the Sanctus Coach and their Coaching Services.
Nature of the relationship
Sanctus (Sanctus London Limited) holds a relationship with The Business to provide Sanctus Coaching to it’s staff.
Sanctus has a team of Sanctus Coaches who are self-employed contractors with Sanctus who deliver Sanctus Coaching within The Business.
Via Sanctus’ relationship with The Business, Sanctus Coaches offer coaching services to staff members (The Clients)
- Nobody in The Business will have access to the personal information shared by Clients with Sanctus and The Coach.
- Discussions with Sanctus Coaches (i.e. during a coaching session) are completely confidential and nothing is shared with Sanctus or The Business.
- Sanctus holds your personal data in form of your name and e-mail address, the details shared when making a booking to see a Sanctus Coach.
- Sanctus will share anonymised, cleaned, quantative data with The Business around overall Sanctus usage.
- Sanctus Coaches may share your personal data with their regulatory bodies for their continuing professional development and coaching credentials.
- Sanctus Coaches may disclose content shared in coaching discussions for their continued professional development, such as supervision. However, they never disclose any identifying personal information.
- Sanctus’ contract with Sanctus Coaches includes that they keep their physical notepads safe and stored away and any digital records sufficiently protected.
- Sanctus holds your personal data for correspondence and appointment scheduling only.
- If you’d like to access, amend or delete any information please contact firstname.lastname@example.org
- If at any time you are concerned or have questions about how we might be handling Your data, please reach out to our Data Protection Officer at email@example.com
Sanctus London Limited (“Sanctus”, “We”, “Us” and “Our”) remain fully committed to the protection of our users privacy at all times. The information contained in this policy has been published to inform you of the way in which any Personal Data (as defined below) you provide us with or we collect from you will be used. Please read this information carefully in order to fully understand how we treat such Personal Data.
We will collect, store, use and disclose Personal Data in accordance with all applicable laws relating to the protection of Personal Data, including the EU Data Protection Directive 95/46/EC, the EU General Data Protection Regulation 2016/679, the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, as amended or superseded from time to time, and any national implementing legislation (“Data Protection Laws”).
For the purpose of Data Protection Laws, in relation to any Personal Data you submit to Sanctus, you will be the data controller and we will be a data processor of such Personal Data.
Personal data we may obtain from you
“ Personal Data ” means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We may obtain and use the following Personal Data about you:
- Any correspondence we have with you should you contact us
- Data you provide when you register to become a user of Sanctus.
- Details of your frequency of use of Sanctus
Where we store personal data
The Personal Data we obtain from you and your Users (including, without limitation, Client Data) may be moved to and stored at a destination within the European Economic Area (“EEA”). Staff members operating within the EEA who work for or on behalf of us may process this information. Such staff members may, among other things, be involved in the provision of support services and the delivery of your and your Users’ request(s) for us to provide the Service.
Without limiting the foregoing, you agree that Personal Data we obtain from you may be processed by our service providers based in countries outside of the EEA for the purposes of providing you with the Service. Such countries may not have laws offering the same level of protection for Personal Data as those inside the EEA; however where such transfers of data occur, we will take steps to prevent the transfer of Personal Data without adequate safeguards being put in place and will ensure that your and your Users’ Personal Data collected in the EEA and transferred internationally is afforded the same level of protection as it would be inside the EEA. For further information on, or a copy of, the adequate safeguards adopted by us for the international transfer of Personal Data, please email firstname.lastname@example.org.
- We store the Personal Data you provide us within the Sanctus Online Booking System that is currently hosted by YouCanBookMe.
- Coaches may store your personal data in their own online physical and digital files.
As the transmission of data via the Internet cannot be assumed completely secure, we cannot guarantee the security of any of your or your Users’ data transmitted to our Website or Service; you are therefore responsible for any risk associated with such transmission. We will however at all times take all reasonable steps to ensure the transmission of your and your Users’ data is executed as securely as possible, and upon receipt of your/their data we will continue at all times to enforce strict security procedures and features in an attempt to prevent any unauthorised access.
How we protect your personal data
We will take reasonable steps to maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your Personal Data.
How we use your personal data
The Personal Data we hold about you may be used in any of the following ways:
- To allow you to book Sanctus Coaching sessions.
- To enable Coaches to claim accreditation and credentials for the coaching they do with you.
- For coaches to confidentially and anonymously share and receive support for their coaching in supervision and training.
- To evaluate the performance and professional integrity of a coach.
- For research and analytics purposes (for example, to improve the quality of the Service).
- To quantitively share usage of Sanctus with your business, with all data anonymised and cleaned of personal information.
- To comply with applicable Laws, court orders, government and law enforcement agencies’ requests.
- To send you further information about our services for which we think you may have an interest. This information will be supplied only where you have given consent.
- To send you further information about our services based on a request we have received from you.
- To provide you with notification about any changes to the Service. We will never supply your or your Users’ Personal Data to third parties unless under the conditions stated beneath this section of our privacy
Disclosure of your information
Disclosure of your and your Personal Data to third parties will only occur in any of the following events:
- We sell or purchase any business or assets. In such case, we may authorise the disclosure of your personal data to prospective sellers or buyers of such business or assets.
- All or the substantial majority of our assets are sold to a third party. In such case, your personal data may be one of the transferred assets.
- The Coach needs to submit the number of Coaching hours they have done with their regulatory body for their accreditation and professional development.
- The Coach discloses anonymous information about coaching discussions in their own supervision, training, mentoring or continued professional development.
- Sanctus evaluates whether the Coach is keeping adequate records of sessions.
Our service providers have to follow our express instructions when processing the Personal Data you or your Users provide and must have in place appropriate technical and organisational security measures to safeguard such Personal Data, and we do not allow them to use this information for their own commercial purposes.
You retain the right to request us to refrain from processing your data for the purposes of marketing. To exercise such right, you may reply to any information we send you, detailing your request that we refrain from sending any marketing correspondence, or you can exercise this same right by contacting us electronically via email at email@example.com.
If at any time we intend to use your data for such marketing purposes however, it is standard practice for us to make you aware in advance of collecting such data.
We may at times provide links on our Website to third party websites, including without limitation those owned or managed by our partner networks, affiliates or advertisers. These websites have separate privacy policies, and we therefore cannot accept any responsibility for the content. As such, choosing to follow these links is a choice you make at your own risk, and we advise that you check these websites’ individual privacy policies before submitting any personal data.
You retain at all times the right to access / amend / delete any Personal Data we hold about you or to exercise your right of data portability or to object to, or restrict, the purposes for which your Personal Data is processed on certain grounds. You may exercise this right by making a request in accordance with Data Protection Laws, by emailing firstname.lastname@example.org.
You may also lodge a complaint with the UK data protection regulator, the Information Commissioner should you be dissatisfied with the way that we handle your Personal Data.
How long we keep personal data for
We will keep your and your Users’ Personal Data for the duration of the Service and in accordance with your instructions or for such periods as may be required by law.
If at any time we make a change to this policy, we will update this page to reflect such change. Where we feel it appropriate, we will notify you by email, however we recommend you review this page periodically to ensure you remain happy with the latest version.
Questions, comments and getting in touch