TFP PRIVACY POLICY
The Facilitation Partnership Limited (TFP) processes basic personal data (i.e. contact details) of its clients, associates, suppliers and supporters. In the case of coaching clients, further personal data which may include their career and life history or other coaching notes may be stored for a limited period.
TFP has a number of individual clients who have found us by recommendation, via our website/s or through an online search directory. As they are individuals, we need to ensure that we have their consent for any contact we may make with them in future.
TFP paper files are kept in a locked office, and computer data is stored on a laptop on which all data is encrypted, password protected, and protected by an anti-virus / anti-malware system.
TFP also uses an internal Customer Relationship Management (CRM) systems to store contact details of prospective clients, clients, associates, suppliers and supporters, and to send targeted email communications to these contacts. TFP undertakes Data Protection policies to store data securely, either in the UK, or in the USA under the conditions of the EU-U.S. Privacy Shield Framework.
TFP’s website uses traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Website users can choose to accept or decline cookies. TFP’s website does not collect any additional personal data, except any information sent via the Contact Us form, which may be stored and used as per paragraph 1 or 2 below.
1. Personal Data of contacts in companies and organisations
A) USED IN TARGETED MARKETING PHONE CALLS
Before making phone calls to an organisation with which TFP has not had contact, TFP will check that the phone number we intend to call does not appear on the CTPS database of companies that do not wish to receive unsolicited calls (e.g. using https://secure.marketscan.co.uk/tpsctpschecker.aspx)
Lawful basis for contacting them: legitimate interest – to offer services which the data subject may require on behalf of their organisation.
Retention of personal data: indefinitely, unless informed of change of phone no, or requested to no longer contact them.
B) USED TO SEND THEM TARGETED AND TAILORED MARKETING EMAILS
Lawful basis for contacting them: legitimate interest – to offer services which the data subject may require on behalf of their organisation.
Retention of personal data: until we are informed that they have left the organisation.
Privacy Statement: we add the following to the TFP email signature used for marketing emails:
TFP stores your name and email address (and phone no if known) securely on our computer, in order to contact you to make you aware of services that we could provide. Please inform us by reply to this email if you no longer wish us to contact you in this way. You can see TFP's privacy policy here.
C) USED TO SEND THEM MARKETING EMAILS FROM THE TFP CRM DATABASE
Lawful basis for contacting them: legitimate interest – to offer services which the data subject may require on behalf of their organisation.
Retention of personal data: until we are informed that they have left the organisation.
Privacy Statement: We will include the following message at the end of TFP marketing emails:
You can see TFP's privacy policy here. TFP Limited respects your time and privacy. We store your name and email address securely, in order to make you aware from time to time of services that TFP could provide. If you no longer wish to receive TFP emails, please unsubscribe using the link below.
2. Personal data of TFP coaching clients
A) USED TO SET UP AND PROVIDE COACHING SESSIONS
TFP stores contact details of prospective coaching clients and may pass them to TFP Associates who may provide specific coaching needs., If the coaching goes ahead, the coach will use the contact details to set up coaching sessions, and possibly for contact between sessions. If the client is contracting on their own behalf, TFP also use their contact details to send them a service agreement.
The TFP coach may also keep notes of coaching sessions to assist in offering appropriate support throughout the process of working with the coachee.
Retention of personal data: for period agreed between coach and coachee (recommended six months, and not normally more than five years, from completion of coaching)
Consent: Signed consent to store and retain personal data is requested from the coaching client before the first coaching session, using a TFP coaching agreement form.
B) USED TO MAINTAIN CONTACT AND MAKE THEM AWARE OF TFP SERVICES
TFP would like to send former coaching clients a periodic greeting email with brief information on TFP services. Opt-in permission will be sought for this from the coachee to receive emails. The emails would be sent from the CRM database, so would include the opt-out message as 1.c) above.
3. Personal Data of TFP Associates
A) USED TO CONTACT THEM BY PHONE, TEXT OR EMAIL IN CONNECTION WITH PROSPECTIVE, CURRENT OR PAST ASSIGNMENTS
Lawful basis for contacting them: ‘contractual/legitimate interest’ – in connection with assignments which they have carried out, or may wish to carry out, on behalf of TFP.
Retention of personal data: indefinitely, unless requested to no longer contact them.
B) USED TO SEND THEM EMAILS FROM THE TFP CRM DATABASE
Lawful basis for contacting them: legitimate interest – to inform them of developments in TFP, or possible work assignments. The email would be sent from the CRM database, so would include the opt-out message as 1.c) above.
4. Personal Data of TFP Suppliers
A) USED TO CONTACT THEM BY PHONE OR EMAIL TO REQUEST PRODUCTS OR SERVICES.
Lawful basis for contacting them: in connection with a contract for goods or services.
Retention of personal data: as long as TFP is likely to require goods or services from them.
B) USED TO SEND THEM EMAILS FROM THE TFP CRM DATABASE
Lawful basis: legitimate interest – they as a provider to TFP may well have an interest in developments in TFP. If they come to the point where they do not have such interest, they have the opportunity to opt out, as 1.c) above.
5. Personal Data of TFP Supporters
A) USED TO SEND THEM EMAILS FROM THE TFP CRM DATABASE
Lawful basis: consent – they as family, friends or acquaintances may well have an interest in developments in TFP. Their consent will be sought to continue sending them updates, and if they come to the point where they no longer have such interest, they have the opportunity to opt out, as 1.c) above.
6. Recording of requests for information or erasure and responses to them
When a request is received to provide personal data held by TFP on a data subject, (a 'subject access request') TFP will respond without delay with the data held on that person, and will record on a list of such requests the request, the date it was received, the response and the date of response.
When a request is received to erase someone’s personal data, TFP will note the request on a list of such requests, to include the date of the request, name of organisation (if applicable), initials of the person concerned and action(s) taken, with date(s), to remove their data from all TFP computer and paper records.
When a request is received for TFP to no longer contact a person, TFP will note the request on a list of such requests, to include the date of the request, name of organisation (if applicable), name of the person concerned and action(s) taken, with date(s), to remove them from contact lists, including the TFP CRM system if applicable. The CRM system may retain their details on a ‘black list’ to ensure that they are not emailed again from the system.
7. Action in the event of a data breach
Should TFP become aware of loss of or unauthorised access to any Personal Data held by TFP:
§ the incident will be investigated by the Business Manager, who will conduct an assessment of the risks arising from the data breach
§ the need to inform the Information Commissioner's Office, data subject(s) and organisations affected will be assessed, and if appropriate they will be notified as soon as practicable
§ if crime is suspected the police will be notified as soon as practicable
§ and steps will be taken to prevent similar loss or unauthorised access in future.
8. Queries or requests for information
If you have any queries on the above, or wish to know what personal information TFP holds relating to you, please contact the Business Manager on office@thefacilitationpartnership.com
