The Libra Partnership Privacy Policy
You can be assured that The Libra Partnership will respect your privacy and confidentiality and take appropriate steps to protect your personal data.
This is the GDPR privacy policy of The Libra Partnership, which is the trading name of The Libra Collective Limited. References to The Libra Partnership in this document should be read as applying to The Libra Collective Limited. James Pereira and Zita Tulyahikayo are the sole directors of The Libra Collective Limited.
Under the EU/UK General Data Protection Regulations, GDPR, The Libra Partnership are the “data controller” and collect personal data about you for the purposes of delivering services to best suit your requirements and preferences as detailed below.
This privacy policy sets out how The Libra Partnership collects and processes your personal data during the course of our business, including any data you may provide at networking events and by telephone, email or post, or through the use of our website.
The Libra Partnership will never sell your personal data to Third Parties for marketing purposes.
Your personal information will never be shared without your permission. Except where we are under a duty of disclosure in order to comply with a legal obligation, where you disclose any criminal or fraudulent activities, where there is a valid court order or witness summons, or there is imminent or likely risk of danger to self or others.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
(1) Reasons for processing your personal data
Under section 6(1)(b) of the GDPR we may collect and process your personal data for the legal bases of:
Consent (for example, professional log of coaching hours, sign-up to newsletters);
Contract for services (for example, coaching, facilitation, training and consulting);
Legal Obligation: the processing is necessary for us to comply with the law (not including contractual obligations) e.g. HMRC purposes;
Vital Interests: the processing is necessary to protect someone’s life; and
Legitimate Interest (registration for events such as Peer Advisory Circles, pilot workshops etc.)
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
(2) What type of personal data is processed?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The type of personal information collected may include, for example:
1. Your name;
2. Contact details: home and/or business address, personal and/or business email address and phone numbers;
3. Name of your employer;
4. Job title;
5. Notes, emails and feedback from coaching sessions, results of questionnaires and psychometric profiles and 360-degree stakeholder reports;
6. Professional Coaching Log: name, contact details and number of coaching hours for the purposes of maintaining professional accreditation with the International Coach Federation (ICF) or training schools. Further information on ICF experience requirements can be found here.
7. Marketing and Communications Data, including your preferences in receiving marketing from us and your communication preferences; and
8. Financial and Transaction Data including bank account and payment card details, services provided and invoicing details.
(3) How is your data collected?
We use different methods to collect data from and about you including through:
Identity, Contact and Financial Data through Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: ask for our services; participate in our coaching activities; request marketing to be sent to you; leave a comment on our LinkedIn Page; or give us some feedback.; and
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU and from events such as conferences and seminars through business cards or attendee lists.
Technical data (automated technologies or interactions) may also be collected should we use an Analytics Provider, such as SquareSpace analytics or Google Analytics, to measure web site usage. Our web site also uses cookies. Full details of the specific cookies that we use and their purpose can be found on our website.
(4) Disclosure of your personal data
We will never disclose your personal data unless required to do so for a legitimate legal reason or given direct specific consent by you. We will never share your data with third parties for their marketing purposes.
We will only share your data with external third parties in the following circumstances.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice;
External parties who we have engaged in order to fulfil our contract with you (e.g. suppliers of training facilities or additional external coaches) or are providing professional services such as legal or tax accounting. Any data shared will be limited to that required to perform the specific, legitimate function.
ICF accreditation (see sections 2.6 and 5)
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
(5) Transferring your personal data abroad
If an audit is required of our coaches’ professional coaching log, in order to verify coaching experience, the personal data will be transferred to the ICF in the US which operates under the EU-US Privacy Shield and is compliant with GDPR. The information in the professional coaching log will only be seen by ICF staff. Client information is never shared or sold to another party or used for any purpose other than the review of the application. Clients listed in the professional coaching log may be contacted by ICF to verify the information. If they are contacted, clients will not be asked about the content of any coaching interactions.
(6) How long is the information held and how is it stored?
The personal data is held for the duration of our business relationship and is stored safely in controlled access hard copy storage (for paper, forms, and notes) and controlled access environments (for emails, downloaded electronic reports and electronic documents).
Personal data from (2.5) above is destroyed securely upon completion of the coaching agreement. Invoices and contracts (2.8) will be retained for as long as is necessary for record keeping and to comply with legal and HMRC requirements.
Personal data from (2.6) above will be retained until is necessary for the successful renewal of ICF accreditation. ICF requires that credentials are renewed every three years and carries out regular audits of applications, including verifying information provided in relation to coaching experience. ICF requires that specific consent is sought for the personal data being held in the coaching log and for it to be shared with ICF should they request it.
Data held for the purposes of marketing (2.7) is processed on the legal basis of Consent and we will periodically reconfirm this consent with you.
(7) Your Rights and access to personal information
Individuals can find out if The Libra Partnership hold any personal information by making a “subject access request.” If we do hold information about you, we will:
• give you a description of it;
• tell you why we are holding it;
• tell you who it could be disclosed to; and
• let you have a copy of the information in an intelligible form.
To make a request for any personal information we may hold you need to put the request in writing by emailing contact@thelibrapartnership.com or sending it to the address provided below.
If you agree, we will try to deal with your request informally, for example, by providing you with the specific information you need over the telephone.
If we do hold information about you, you can ask us to remove it or correct any mistakes by contacting us at contact@thelibrapartnership.com or writing to the address below. We will endeavour to comply with any requests unless there is a valid legal reason that means we cannot.
(8) Complaints or queries
We encourage people to let us know if they think that our collection or use of information is unfair, misleading or inappropriate. We also welcome any suggestions for improving our procedures.
The Libra Partnership’s privacy policy was drafted with clarity in mind. While it contains the main aspects of our collection and use of personal information and technical data, it does not provide exhaustive detail of all. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
If you have any concerns, while we would hope that you would address them to The Libra Partnership the first instance, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
(9) Changes to this Privacy Policy
This Privacy Policy was created on 12th March 2020. We reserve the right to update and change this Privacy Policy from time to time to reflect any changes to the way in which we process your personal data or changing legal requirements. Where these changes are significant, we will identify them in this section of the policy for ease of reference.
(10) How to contact The Libra Partnership
If you want to request information about our privacy policy, you can email us at contact@thelibrapartnership.com or write to: James Pereira QC, c/o Francis Taylor Building, Inner Temple, London EC4Y 7BY.