1.0 Our core beliefs regarding client and user privacy and data protection
In everything we do, we seek to model the three ARC Qualities at the heart of Richard’s work: authenticity, responsibility and courage. Where data is concerned, this means:
- We believe we have a duty of care to the people whose data we hold
- We believe in knowledge as a force for good, not a means of manipulating others for personal or commercial gain – hence we will never sell, rent or otherwise distribute or make public your personal information
- We loathe spam as much as you do
- We believe it’s important to share new ideas, particularly those from outside one’s own ‘echo chamber’
2.0 Relevant legislation
We endeavour to comply with the following national and international legislation with regards to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
We’re based in the UK but still subscribe to the spirit and standards outlined in the EU legislation mentioned above. Our website’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely to be compliant with the data protection and user privacy legislation set out by many other countries and territories as well.
The data we collect in the course of our work is more sensitive. We’ll cover that in Section 4.
3.0 Personal information our website collects, why we collect it and your rights with regard to that data
This website collects and uses personal information for the following reasons:
3.1 Measuring the use and effectiveness of this website
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you. However, Google do not grant us access to this. We consider Google to be a third-party data processor (see section 6.0 below).
The cookie set by Google Analytics is _ga, which expires after 2 years. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
This website also uses the following cookies, which are built in by WordPress, the application through which this website is built and updated:
- X-mapping-kjicghkc – a load-balancing cookie, and helps to optimise the performance of the site. It contains a random number and expires at the end of your session
- wordpress_test_cookie, which expires at the end of the session
- wp-settings-1, which expires after 1 year
- wp-settings-time-1, which expires after 1 year
- _atuvc – a cookie used by AddThis, an app built into this website that enables you to share pages on the site with other people via popular social media websites. This cookie expires after 2 years
3.2 Contacting you with things we genuinely believe you’ll find useful
When it comes to email marketing, we’ve never believed in simply uploading all of our contacts to a database and spamming all and sundry. We only ever send automated emails to people who have knowingly signed up to a mailing list. Should you request free chapters from Richard Boston’s books or access to the Resources offered on our website to support you as a reader of Richard’s books, the data that you submit to us will be forwarded to MailChimp, the third-party data processor (see section 5.0 below) that we use for email marketing. The data you submit will not be stored within this website’s own database but we may periodically download it to our internal computer system to facilitate communication with you.
We collect data on the nature of your job and the organisation you work for to help us understand who is using the resources on our website and tailor them accordingly. It also helps us exclude you from any mailings if those mailings are unlikely to appeal to someone in your position or industry.
While your email address remains within the MailChimp database, you will receive occasional newsletter-style emails from us. We don’t believe in frequently bombarding you with stuff that’s no use to you. So we will email you intermittently with news, links to blogs and alerts when new books come available. Our intention is to do so no more than three times a year.
Your data will remain within MailChimp’s database for as long as we continue to use their services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before signing up for this content. If you’d like to view MailChimp’s own policies, you’ll find them here.
3.3. Your right to access and control your personal information
If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by emailing us at email@example.com
Please contact us in the same way if you require details of the personal information which we hold about you, or if you believe any information we are holding on you is incorrect or incomplete.
3.4 Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
4.0 How we store individual client data
As psychologists and coaches, we take notes during the course of our work as those notes help us deliver on the work we’re contracted to do. These are stored in one or both of two places: on paper and on computers. Notes held on paper are stored in a locked cabinet when not in use, and shredded or burned on site when the time comes to destroy them. Those held electronically are stored on computers protected by passwords, antivirus software and encryption – details of which are available by contacting us directly. The British Psychological Society advises that client notes be kept for seven years. Given the nature of our relationships with client organisations, we keep records for those seven years or until our work with the organisation in question ends, whichever is later. So if you wish for your records to be destroyed prior to that, please let us know in writing using the details below.
Where files are synchronised across devices or stored in the cloud, they are encrypted at source. Our policy is to never send psychometrics or similarly sensitive personal data via email. Should this prove unavoidable for some reason (e.g. when a coach sends you their ‘reflective feedback’), then such data will be password protected, with the password provided by some other medium (usually SMS). Individual client data is never stored or transported between sites on USB sticks or other portable media.
If you are sending reflective feedback to us, then we recommend you also password protect the document and send the password via SMS.
4.2 Psychometrics and other online questionnaires
As discussed in section 5.0, we use a range of providers. It is our understanding that all of them are GDPR compliant.
The vulnerabilities of email security mean that we will not send psychometric reports by email without your written permission unless they are password protected.
4.3 Contact details
Naturally, each member of the team holds the names and contact details of their clients and other contacts. We do not keep a central database of everyone’s contacts. However, for specific projects we may share the contact details of participating individuals. We will only do so when this is necessary for project-related communications with those participants.
4.4 Sharing information about you
When two or more LeaderSpace consultants are working together with the same participants, we often compare notes to help us coach more effectively. If this is the case, this will always be made clear to all participants. Technically, as we use an associate model, the majority of our consultants are not LeaderSpace employees. However, we need to treat them as staff to provide the level of service our clients expect. Thus, each of them signs up to this data protection policy as part of their contract with us and the information we share with them is limited to the projects on which they are working.
Our default is that we do not share personal client information with other third party organisations. The only exceptions to this rule are as follows:
- When an individual client’s employer asks for attendance data
- When generating certain MBTI (psychometric) reports, we may be required to enter the client’s ‘best fit’ MBTI type – thus we are ‘sharing’ that data with the publisher of the MBTI
- When including participants in emails to fellow participants and/or the commissioning client (i.e. the organisation paying for our services)
- When the team member working with you is operating in a freelance capacity, in which case they will be required to adhere to the same policies as LeaderSpace
- When the individuals have given their express permission
- When quoting feedback anonymously to give other clients and potential clients a feel for our work – where possible, we would seek permission to use these quotes and we will always take care to ensure anonymous feedback is truly anonymous
- During coaching supervision, where the ‘data’ is spoken and not recorded
- When we are required to do so by law
4.5 Your rights
The following individual rights under GDPR apply to the data we hold:
- The right to be informed
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to object
- The right not to be subject to automated decision-making including profiling
The right to data portability in the GDPR applies only to personal data an individual has provided to a controller, where the processing is based on the individual’s consent or for the performance of a contract and when processing is carried out by automated means. We don’t use automated processing.
LeaderSpace Asia-Pacific is a separate legal entity regulated by Australian law and operating on similar principles to LeaderSpace in the UK. No personal data flows between the two organisations, except where members of those two organisations have been specifically and explicitly contracted to work together with the client organisation.
4.6 Your right to access this data
The size of our business and the nature of this data means we may need to make a small charge if you request the data. On some occasions, we may be unable for legal or ethical reasons to share some of the data we might hold. The clearest examples are where we are privy to sensitive management information or references / feedback provided in confidence by others. Under the GDPR, this kind of data is protected if it is judged likely to “prejudice the business or other activity of the organisation”.
5.0 Data breaches
We will report to the ICO and any and all relevant persons and authorities any unlawful data breach of our website’s database, our computers or our paper-based storage within 72 hours of the breach, if it is apparent that personal data stored in an identifiable manner has been stolen. If the breach pertains to the database(s) of any of our third-party data processors we will take the same action within 72 hours of them notifying us of such a breach.
6.0 Data controller
The data controller for this website and all activities conducted by LeaderSpace Ltd, is LeaderSpace Ltd, UK company number 6591839.
Flat 11 Clifton Down Mansions, Bristol BS8 2XJ.
According to the ICO, the nature of our business and scale of our operations mean there’s no need for a dedicated Data Protection Officer. If you have any questions or concerns, please contact our Managing Director, Richard Boston.
7.1 Change Log
May 2018: updated to reflect GDPR.
June 2019: updated to reflect our evolving practice and ongoing risk assessments with regard to data protection.
August 2019: updated to include references to SurveyMonkey’s data policies.
January 2021: updated to reflect the end of the transition period for the UK’s exit from the European Union.
February 2023: updated to include references to ‘reflective feedback’ and the change to our registered company address.