Introduction

As with all businesses, the IRCM CIC needs to gather and use certain information about individuals and organisations.

The information gathered and used includes Students, Coaches, Mentors, Formal Education Bodies, Private Commercial Training Organisations, Professional Bodies, Support Groups, Commercial Organisations, Consumers, Complainants, Respondents, Third-parties, the IRCM CIC team, as well as other people the organisation has a relationship with or may need to contact.

Where available, we also collect data left in the comments form.

This policy describes how this personal data is collected, handled, and stored to meet the company’s data protection standards – and to comply with the law.
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Why does this policy exist?

This data protection policy ensures the IRCM CIC:

• • Complies with UK Data Protection Legislation and follows good practice.
  • Protects the rights of Students, Coaches, Mentors, Formal Education Bodies, Private Commercial Training Organisations, Professional Bodies, Support Groups, Commercial Organisations, Consumers, Complainants, Respondents, Third parties, the IRCM CIC team, and others.
  • Is open about how it stores and processes organisations and individual’s data
  • Protects itself from the risks of a data breach
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Data Protection Legislation

The Data Protection Act 2018 (https://www.gov.uk/data-protection) controls the use of your personal information by individuals, organisations, and the government.  The IRCM CIC upholds the ‘data protection principles’ and uses all personal or organisational data:

• • • transparently and lawfully.
    • for a specific, explicit purpose or reason.
    • in a way that is adequate, relevant, and limited only to what is necessary.
    • in a way that is adequate, relevant, and limited to provide the service, product, or resolution.
    • accurate and where applicable, kept up to date.
    • kept only for as long as necessary.
    • maintained in a way that ensures the security of that personal data, including protection against unlawful or unauthorised processing, access, loss, destruction, or damage.
    • in line with the information provided on this and other IRCM CIC website pages.

As defined in the UK GDPR means “‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, 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”.
(https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/what-is-personal-data/what-is-personal-data/)
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Controller’s contact details:

The Finance Director is the controller for the personal information processed by the IRCM CIC unless otherwise stated.

Although we can be contacted through our Registered Office address, the quickest way to contact us is through the IRCM CIC’s Contact Us webpage - https://ircmcic.org/contact-us/.

International Regulator of Coaching and Mentoring CIC
Registered Office:
27 Old Gloucester Street
London
WC1N 3AX
United Kingdom
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How does the IRCM CIC receive information?

Most of the personal information we process is provided to us directly by a Consumer or anyone within the industry, for one of the following reasons:

• • Filling in the Contact us form.
  • Subscribing to the IRCM CIC’s newsletter.
  • Unsubscribing from the IRCM CIC’s newsletter.
  • Joining the IRCM CIC’s Directory as REGISTERED, LISTED or upgrading to ACCREDITED.
  • Submitting a request or complaint through the Ombudsman Service
  • Being included in a request or complaint submitted through the Ombudsman Service.
  • You are representing your organisation.
  • Completing a comments form.
  • Being a member of the team.
  • Joining the team.
  • Sub-contracting to or contracting your services/products for the benefit of the IRCM CIC and the community.
  • Contact from the IRCM CIC’s social media platform(s).
  • Any other valid contact method e.g. through a member of the IRCM CIC’s team.
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People, Risks, and Responsibilities

Policy scope

This policy applies to:

• • The IRCM CIC team in all locations, including international locations.
  • The locations of permanently based local and virtual team members.
  • The complete team of the IRCM CIC.
  • All contractors, suppliers and other people working on behalf of the IRCM CIC.
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This policy applies to all personal data that the IRCM CIC holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 2018.  This can include:

• • Names of individuals, including prefixes and suffixes
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • All images, including photographs, logos, and any other image representing you
  • Listed, Registered, or Accredited information
  • IRCM CIC Ombudsman Service Register
    (Register of Facilitation and Discussion requests, Formal Complaints; Appeals, and Outcomes, Actions, Recommendations, and Sanctions)
  • plus any other information relating to individuals, organisations and/or their business.
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Data protection risks

This policy helps to protect the IRCM CIC from some very real data security risks, including:

• • Breaches of confidentiality.
    For instance, information being given out inappropriately or without the knowledge of the individual or organisation.
  • Failing to offer choice.
    For instance, all individuals within the reason their data is held by the IRCM are free to choose how the company uses data relating to them.
  • Reputational damage.
    For instance, the company could suffer if hackers successfully gained access to sensitive data.
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Responsibilities

Everyone who works for or with the IRCM CIC has responsibility for ensuring data is collected, stored and handled appropriately, and that it is processed in line with this policy and data protection principles.

However, some members of the team have one or more key areas of responsibility:

The Company Directors are ultimately responsible for ensuring that the IRCM CIC meets its legal obligations.

The Data Protection Officer is responsible for:

• • Keeping the Company Directors and the IRCM CIC team updated about data protection responsibilities, risks and issues.
  • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
  • Arranging data protection training and advice for the people covered by this policy.
  • Handling data protection questions from staff and anyone else covered by this policy.
  • Dealing with requests from individuals and organisations to see additional data the IRCM CIC holds about them (also called ‘subject access requests’).
  • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

The IT Manager/Webmaster is responsible for:

• • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
  • Performing regular checks and scans to ensure security hardware and software is functioning properly.
  • Evaluating any third-party services, the company is considering using to store or process data. For instance, servers and cloud computing services.

The Marketing, Business Development, Future Development, and Register Directors are responsible for:

• • Approving any data protection statements attached to communications such as emails and letters.
  • Addressing any data protection queries from journalists or media outlets like newspapers, and social media.
  • Where necessary, working with all staff to ensure marketing initiatives abide by data protection principles.
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General staff guidelines

• • The only people able to access data covered by this policy should be those who need it for their work.
  • Data is not to be shared informally.  When access to confidential information is required, this can be requested from the relevant Director.
  • The IRCM CIC will provide training to the whole IRCM CIC team to help them understand their responsibilities when handling data.
  • The IRCM CIC team should keep all data secure by taking sensible precautions and following the guidelines below.
    • In particular, strong passwords must be used and they should never be shared.
    • Personal data should not be disclosed to unauthorised people either within the company or externally unless specifically required for audit purposes.
    • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
    • The IRCM CIC team should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
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Data storage

These rules describe how and where data should be safely stored.  Questions about storing data safely can be directed to the IT Manager/Webmaster or Data Protection Officer.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• • When not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • The IRCM CIC team should make sure paper and printouts are not left where unauthorised people could see the pages i.e. on a shared printer, or desk in a shared or open office.
  • Data printouts must be shredded and disposed of securely when no longer required.

When data is stored electronically it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

• • Data must be protected by strong passwords that are changed regularly and never shared between the IRCM CIC team unless specifically required.
  • If data is stored on removable media these should be kept locked away securely when not being used.
  • Data should only be stored on designated drives and servers and should only be uploaded to approved cloud computing services.
  • Data should be backed up frequently.  Those backups should be tested regularly, in line with the company’s standard backup procedures.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones unless there is a valid reason. Immediately the data is no longer required; it should be deleted.
  • All servers and computers containing data should be protected by approved software and a firewall.
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Data use

Personal data is of no value to the IRCM CIC unless it has received the personal data for a specific reason.  However, it is of additional value when personal data is accessed and used for reasons not designated i.e. loss, corruption or theft:

• • When working with personal data, each member of the IRCM CIC team should ensure the screens of their computers are always locked when left unattended.
  • Personal data should not be shared informally. In particular, it should never be sent by email as this form of communication is not secure, unless communicating with the person or for a specific reason previously identified.
  • Data must be encrypted before being transferred electronically.  The IT manager/Webmaster can explain how to send data to authorised external contacts.
  • Personal data should never be transferred outside of the European Economic Area unless the personal data relates to an individual outside the European Economic Area.
  • The IRCM CIC team should not save copies of personal data to their own computers. Always access and update the central copy of any data unless there is a valid reason.  Immediately the data is no longer required; it should be deleted.
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Data accuracy

The law requires the IRCM CIC to take reasonable steps to ensure data is kept accurate and up to date.

Unless it is specifically stated on the IRCM CIC site i.e. IRCM CIC Directories, it is the responsibility of all members of the IRCM CIC team who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible:

• • Data will be held in as few places as necessary.  Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming an individual’s details when they call.
  • The IRCM CIC will make it easy for data subjects to update the information the IRCM holds about them.
  • Data should be updated as inaccuracies are discovered.  For instance, if an individual can no longer be reached on their stored telephone number or email address, it should be removed from the database
  • It is the Business Development Manager’s responsibility to ensure all business development related databases are checked against industry suppression files every six months.
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Subject access requests

As detailed under ‘Your data protection rights’ below, all individuals who are the subject of personal data held by the IRCM CIC are entitled to:

• • Ask what information the company holds about them and why.
  • Ask how to gain access to it.
  • Be informed of how to keep it up to date.
  • Be informed of how the company is meeting its data protection obligations.

If an individual contacts the IRCM CIC requesting this information, this is called a subject access request.

Subject access requests from individuals should be made as determined under the ‘Controllers Contact Details’ (above).  The Data Protection Officer can supply a standard request form, although individuals do not have to use this.
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Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, the IRCM CIC will disclose requested data.  However, the Data Protection Officer will ensure the request is legitimate, seeking confirmation from the Board and from the company’s legal advisers, where necessary.
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Providing information

The IRCM aims to ensure that individuals are aware that their data is being processed and that they understand:

• • how the data is being used
  • how to exercise their rights

To these ends, the company has a Data Privacy Statement setting out how data relating to individuals is used by the company.
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Your data protection rights

The IRCM CIC is obligated to make you aware of your rights under Data Protection law.

The rights available to you depend on the reason the IRCM CIC is processing your information.
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Your right to access

You have the right to ask us for copies of your personal information.  Although there are some exemptions, the IRCM CIC recognises that this right always applies.
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Your right to rectification

If you have reason to believe that the information the IRCM CIC holds about you, then you have the right to ask for it to be rectified.  This also applies to information that you believe is incomplete.
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Your right to erasure

In certain circumstances, you have the right to request that your personal information be deleted.  The exemption to this is the information the Ombudsman Service is required to hold in relation to a request or complaint in which you are involved.
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Your right to restriction of processing

In certain circumstances, you have the right to request that the IRCM CIC restricts the processing of your information.

This may occur when you have challenged the accuracy of your data, or you have raised concern over the use of your data.
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Your right to data portability

This only applies to your personal information you have submitted to the IRCM CIC directly.  You have the right to ask that we transfer the information you gave us to you.

The IRCM CIC will provide the data you refer to in a commonly used and machine-readable form.  Before any data is sent to you, you will be asked to confirm your identity.

Depending on the reason for holding your data, the IRCM CIC may not delete the data automatically.

You may request that the data is sent to another organisation, and where this is the case, the IRCM CIC will ask for you to confirm your identity and provide your reason for the other organisation to receive this information from the IRCM CIC and not from you directly.
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Although you are not required to pay any charge for exercising your rights, where your request can be deemed to be excessive, the IRCM CIC may request a reasonable fee to deal with your request.
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The IRCM CIC has one month to respond to you.
In certain circumstances, the IRCM CIC may need extra time to consider your request and can take up to an extra three months.  If this additional time is needed, the IRCM CIC will let you know within one month that it needs more time and the reason.
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IRCM CIC reserves the right to change this statement at any time, without prior announcement.