Privacy policy

Contact details

Christina Macnamara Ltd is the data controller for the information described in this policy. 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

I do not have, and am not required to have, a Data Protection Officer.

Scope

This policy covers information collected through this website, my booking and enquiry forms, and my mailing list.

Coaching clients receive a separate client privacy notice covering the information I hold once we are working together, including session notes.

If I coach you through an employer's programme or a coaching platform, that organisation is usually the controller and its own notice applies.

Enquiries and introductory calls

When you get in touch or book an introductory call, you give me your name, your email address, your telephone number if you choose to provide it, and whatever you tell me about what you are looking for.

People often include information about their neurodivergence, mental health or disability. UK law treats information of that kind as special category data and sets a higher bar for holding it.

I keep what you tell me rather than deleting it once I have replied, and it goes into my client management system so that I have read it before our call.

My lawful bases

I hold your enquiry because the processing is necessary to take steps at your request before entering a contract, under Article 6(1)(b) of the UK GDPR, and because I have a legitimate interest in replying properly, under Article 6(1)(f).

Where your enquiry includes information about your health, neurodivergence or disability, I rely on your explicit consent under Article 9(2)(a). There is a separate box for this on my booking form, unticked by default. You are not required to tick it in order to make an enquiry, and we can discuss anything you would rather not put in writing on the call instead.

If you email me directly rather than using the form, there is no box. Where an email contains health information, I will confirm in my reply that I am keeping it, and you can tell me not to.

You can withdraw your consent at any time by emailing me, and I will delete the information.

If you go on to book coaching, your enquiry becomes part of your client record and the client privacy notice applies. If you do not, I hold it for six years, because people often make contact and then return to the idea a long time later. You can ask me to delete it sooner.

I do not add you to any mailing list from an enquiry unless you have asked to be added. I do not use enquiries for advertising, nothing is decided by automated means, and I do not use your information for profiling.

Mailing list

If you subscribe to my mailing list, I hold your name and email address.

I send these emails on the basis of your consent, under Article 6(1)(a) of the UK GDPR. You can unsubscribe from any email, and I will remove you from the list without undue delay. I hold your details until you unsubscribe.

My email platform records whether an email has been opened and which links have been clicked. It does this using a small image embedded in the email. I use this to see which subjects are useful.

Cookies and analytics

A cookie is a small file stored on your device when you visit a website.

Strictly necessary cookies make the site work and keep it secure. These do not require your consent. They include a security cookie set by leadconnectorhq.com, the platform behind my booking and enquiry forms, which lasts about thirty minutes, and a cookie recording your own cookie choices.

Analytics cookies are set by Google Analytics, which tells me which pages are visited and where visitors arrive from. These are _ga and _ga_ followed by a property identifier, both lasting two years. They are not set unless you accept them, and you can change your choice at any time.

If you subscribe through the form on this site, my email platform stores a record on your device so that the form is not shown to you again. This lasts around twelve months.

No non-essential cookies are set unless you accept them.

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 see names and contact details, not what you told me about yourself.
• Software providers. I use a client management and booking platform, an email marketing platform and a payments provider. Each acts on my instructions and cannot use your information for its own purposes.
• My accountant, for financial records only.
• My insurer or a legal adviser, in the event of a claim.

The names of these services are available on request.

Transfers outside the UK

Some of the services above 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.

Emergency contacts

Coaching clients give me an emergency contact name and telephone number when they sign their coaching agreement. If that is you, I hold only your name and number, and I would use them only if I were seriously concerned about that person's safety.

I hold this information under my legitimate interests, Article 6(1)(f) of the UK GDPR. If I ever had to act on it, I would be relying on the protection of someone's vital interests, under Articles 6(1)(d) and 9(2)(c).

I hold emergency contact details for six years after that person's coaching with me ends, in line with the rest of their client record.

I ask every client to inform their emergency contact that they have given me these details. If you were not told, you may ask me to delete them. You have the same rights over this information as anyone else, and you can exercise them by emailing me.

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. You can contact me by email or telephone rather than using a form. The only consequence of not giving me your details is that I may not be able to answer your question or arrange a call.

Changes to this policy

I may update this policy.

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