Client privacy notice

Contact details

Christina Macnamara Ltd is the data controller for the information described in this notice. The company is registered in England and Wales under number 11164717, with its registered office at Henleaze Business Centre, Harbury Road, Bristol, BS9 4PN.

Email: info@christinamacnamara.com

ICO registration number: ZC218084

What information I collect, use, and why

Most of this comes from you, either when you first get in touch or during our work together.

• Your name and contact details, together with what you told me when you first got in touch and during our introductory call.
• Notes of our sessions, recording what we discussed and the actions we agreed.
• The name and telephone number of your emergency contact.
• Invoices, payment dates and amounts. Your card details are handled by my payments provider, and I never see them.
• Where your coaching is funded through Access to Work, the information that scheme requires in order to process claims.

I use this information to arrange and deliver your coaching, to prepare between sessions, to invoice you and keep proper financial records, and to meet the requirements of my professional credential and my insurance.

Our conversations may involve your neurodivergence, mental health or disability. UK law treats information of that kind as special category data and sets a higher bar for holding it.

Nothing about your coaching is decided by automated means. I do not use your information for profiling, marketing or advertising, and I do not sell it.

My lawful bases

I hold your contact details, session notes and booking records because the processing is necessary to perform our contract, under Article 6(1)(b) of the UK GDPR.

Where my notes record information about your neurodivergence, mental health or disability, I rely on your explicit consent under Article 9(2)(a). You give that consent when you sign your coaching agreement, and you can withdraw it at any time by telling me. If you withdraw it, I will stop recording that kind of detail and delete what I already hold, and your coaching continues unaffected.

I keep invoices and financial records because tax law requires me to, which is a legal obligation under Article 6(1)(c).

I also keep a limited record of the dates we worked together and the fees paid, under my legitimate interests in holding insurance, maintaining my ICF credential and being able to answer a complaint or legal claim. That is Article 6(1)(f), and where the record touches on special category information, Article 9(2)(f), which covers the establishment and defence of legal claims. This part of the record is not held on the basis of your consent, so withdrawing your consent does not remove it.

How I store your information

Session notes are held locally, on my own encrypted device. Bookings, invoices and correspondence are held in my client management system, my payments provider and my email provider, each of which acts on my instructions and cannot use your information for its own purposes. The names of these services are available on request.

Email and video calls are not fully secure. I use ordinary commercial services for both rather than specialist encrypted ones, which is the normal position for online coaching.

If I ever move session notes into a hosted service, I will tell you before I do so and update this notice.

Who I share information with

• Technical support staff at the companies whose software I use, when they are resolving a problem. This includes the content of email correspondence held in my client management system.
• A business assistant, for invoicing and scheduling. They do not have access to session notes.
• My accountant, for financial records.
• The International Coaching Federation, which requires a log of client names, contact details and session dates and may check it when I renew my credential. No session notes or health information are attached to that log.
• Access to Work, where your coaching is funded that way. The Department for Work and Pensions receives your name, the dates you attended and the number of sessions claimed, but not the content of our sessions. DWP decides for itself what it does with that information and is a separate controller, so its own privacy notice applies.
• My insurer or a legal adviser, in the event of a claim or complaint.

I discuss my coaching practice in supervision, training and professional development without identifying anyone, and no records are shared.

Transfers outside the UK

Some of the services I use are based in the United States and Australia, so information held in them is processed outside the UK.

Where a provider is certified under the UK Extension to the EU-US Data Privacy Framework, I rely on that. Where it is not, the transfer is covered by standard contractual clauses together with the UK International Data Transfer Addendum, or by the UK International Data Transfer Agreement.

How long I keep information

• Session notes: six years after our work together ends.
• Invoices and financial records: six years from the end of the relevant financial year, as HMRC requires.
• Emergency contact details: six years after our work together ends, in line with the rest of your record.

Your data protection rights

You have the right to ask me for a copy of the information I hold about you, to have it corrected or erased, to restrict or object to the way I use it, to receive it in a portable form, and to withdraw your consent.

Please email me and I will respond within one month, at no charge.

Giving me your information is your choice. Without your contact and payment details I cannot arrange or invoice for coaching, but you decide how much you tell me about your circumstances.

How to complain

If you have any concerns about my use of your personal information, you can make a complaint to me at info@christinamacnamara.com.

If you remain unhappy with how I have used your data after raising a complaint with me, you can also complain to the Information Commissioner's Office.

Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
ico.org.uk/make-a-complaint