Effective Date 04 March 2025
This Privacy Policy explains how we use Personal Information which we collect about individuals in relation to the use of the Coaching with Chemistry coach matching service and provision of coaching services.
We take the security of your Personal Information very seriously. We use a combination of technical, organisational and physical security measures to protect your Personal Information in line with our obligations under data protection law.
a. Sources of Personal Information
We obtain Personal Information from your employer or another third party if you have been referred by them for coaching.
We obtain Personal Information directly from you when you complete our chemistry matching questionnaire or use our coaching services.
b. Types of Personal Information Collected
The Personal Information we hold and process may include:
c. Uses of Personal Information
The main purposes for which we use Personal Information are to:
d. Lawful Basis for Uses of Personal Information
We are committed to collecting and using Personal Information in accordance with applicable data protection laws. By law, we must have a legal justification, known as a lawful basis, in order to use your Personal Information for the purposes described in this Privacy Policy. Depending upon the purpose, our lawful basis will be one of the following:
Where we rely on the lawful basis of legitimate interests, the interests being relied upon will usually be:
In connection with the purposes set out above, we will share Personal Information with:
The Information Commissioner’s Office (ICO) provides a helpful guide to your rights under GDPR in relation to automated decision making and profiling. More information about your rights can be found here: ICO rights related to automated decision making including profiling
What is Automated Individual Decision Making?
Automated individual decision-making is a decision made by automated means without any human involvement.
Coaching With Chemistry does not use automated decision making. Our machine learning algorithm predicts coaching chemistry. These predictions are reviewed by a human before being passed on to you. As a client you will be offered a shortlist of coaches to review and meet with for a chemistry session. The final decision of which coaches to meet with and which coach to work with is yours.
What is Profiling?
Profiling is automated processing of personal data to evaluate certain things about an individual.
Coaching With Chemistry does use profiling to evaluate which coaches we think you will have ‘coaching chemistry’ with.
What Data Do We Use In Our Profiling?
Our questionnaire will ask you questions which we believe are relevant to what we call in coaching, the ‘working alliance’.
We ask questions about you and what you want from your coach.
Our questions are designed to help us understand aspects of your personality, your coaching goals and the coaching intervention style that would best suit you.
What Data Don’t We Use In Our Profiling?
We do not use any special category of data in our matching. Special category data is personal data that needs more protection because it is sensitive. It includes data revealing, for example racial or ethnic origin, health, or sexual orientation.
We keep Personal Information for as long as is reasonably required for the purposes explained in this Privacy Policy.
We also keep records – which may include Personal Information – to meet legal, regulatory, tax or accounting needs. For example, we are required to retain an accurate record of your dealings with us, so we can respond to any complaints or challenges you or others might raise later.
Unless we have agreed otherwise with your employer or any third party who has referred you to us, we will retain your data for 12 months from the conclusion of your using our coaching services.
You have legal rights under data protection laws in relation to your Personal Information.
We aim to respond to all valid requests within one month. It may take us longer if the request is particularly complicated or you have made several requests. We’ll always let you know if we think a response will take longer than one month. We may also ask you to provide more detail about what you want to receive or are concerned about.
We may not always be able to do what you have asked. This is because your rights will not always apply. We will always explain to you how we are dealing with your request. In some circumstances (such as the right to erasure or withdrawal of consent), exercising a right might mean that we can no longer provide our service to you.
Your rights are as follows:
Access to your Personal Information
You may ask us for a copy of your Personal Information together with specified details about how we use your information. This is commonly known as a ‘subject access request’.
Rectification of your Personal Information
We do our best to ensure that your Personal Information is accurate and kept up to date. If you believe your information is inaccurate or incomplete, then please contact us to request that we amend or update it.
Erasing your Personal Information
You may ask us to erase your Personal Information, but this right only applies in certain circumstances, e.g. where:
Restricting processing of your Personal Information
You may ask us to stop using your Personal Information in certain circumstances such as:
Data portability
In some cases, you can ask us to transfer Personal Information that you have provided to us to another third party of your choice.
Right to object
You can object if you no longer wish us to process your personal data
Automated decision making and profiling
You have the right not to be subject to a decision using your Personal Information which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you.
Coaching With Chemistry does not use automated decision making.
Withdrawing consent
In some circumstances we ask for your consent to use your Personal Information. You are free to withdraw your consent at any time.
If it is the case that we need your consent to provide you with a particular service and you wish to withdraw your consent, we may no longer be able to provide our service to you. Where that is the case, we will inform you before taking any action.