1.Information we collect
When you visit our website
You are free to explore the Lead the Way Consulting website without providing any Personal Information about yourself. When you visit the website we collect Navigational Information. This refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the “Navigational Information” section below.
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, email address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into with us, and information about you that is available on the Internet, such as from Facebook, LinkedIn, Twitter, Instagram and Google. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Information about children
Our website is not aimed at addressing anyone under the age of 13. As such, we do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under age 13 without verification of parental consent, we take steps to remove that information from our servers.
2. How we use information we collect
Storage and sharing
Any Personal Information we have will be stored securely by us. Lead the Way Consulting is made up of three people. Each of the three will have access to both the Personal Information and general information about the work that is being carried out. In order to ensure our effectiveness and that we give you the best possible service, we have a clinical supervisor. In discussing our work with our supervisor, we are careful to ensure we do not share anything that makes you identifiable.
We never sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
Use of Navigational Information
We use Navigational Information to operate and improve your experience of our website. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalised information about Lead the Way Consulting.
Client testimonials and comments
We post client testimonials and comments on our website, which may contain Personal Information. We obtain each client’s consent via email prior to posting the client’s name and testimonial.
Social media platforms
Retention of Personal Information
We retain Personal Information for as long as the individual or their employer is in receipt of services from Lead the Way Consulting, plus up to a maximum of 3 years (as long as we consider it potentially useful in contacting you about our services). After this we securely delete the information.
However, we will maintain your Personal Information longer where required to comply with our legal obligations, resolve disputes and enforce our agreements and for tax or accounting purposes, to ensure we would be able to defend or raise a claim, or where we have a specific need to retain. Though we will generally not keep personal data for longer than seven years following the last date of communication with you.
If a client makes a specific request for their data to be deleted sooner and it does not conflict with any legal requirements to hold data for longer, we will honour the request.
Complying with the law
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
3. Navigational Information
We use “cookies” to help you personalise and enhance your online experience. A cookie is a text file that is placed on your hard disk by a web server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalise pages on our website for instance, by completing a form, a cookie helps us to recall your specific information on subsequent visits. When you return to the same website, the information you previously provided can be retrieved, so you can easily use the customised features.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the webpages you visit.
We sometimes use Google Analytics to help us understand how visitors are using and engaging with our website. This allows us to make improvements to our web services and your online experience. The Google Analytics tracking tool uses a number of cookies to collect information and report website usage statistics and does so without personally identifying individual visitors to Lead the Way Consulting.
4. Social Media and Marketing
Our legal basis for contacting you is our legitimate interest – to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy.
You always have a choice as to whether and how you want to receive communications about our content and services. As inbound marketers, your permission or consent is central to how we engage with you, for example, you will need to specifically opt-in to receive blog notifications from us.
If you ever want to change your contact preferences, or opt out of communications, you can do this at any time by contacting us.
If you choose not to be contacted by us we will never send you marketing communications, but we may keep your details on a ‘suppression list’ to ensure you aren’t contacted.
You may also let us know via our general email firstname.lastname@example.org or at our address: Lead the Way Consulting, 38 Braunton Road, Aigburth, Liverpool, L17 6AP.
We monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
6. Your Rights
Under GDPR and the new Data Protection Act 2018 (DPA 2018), you have rights as an individual which you can exercise in relation to the information we hold about you. If you have concerns about how we are using your data, you can read more about your rights here – https://ico.org.uk/your-data-matters/raising-concerns/
Lead the Way Consulting tries to be as open as it can be in terms of giving people access to their Personal Information. Individuals can find out if we hold any Personal Information by making a ‘subject access request’ under DPA 2018.
No fee usually required
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to carry out a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
To make a request to Lead the Way Consulting for any Personal Information we need you to put the request in writing addressing it to the Office Manager. Please see the “How to contact us” section below.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
7. Complaints or queries
Lead the Way Consulting tries to meet the highest standards when collecting and using Personal Information. For this reason, we will take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
If we receive a complaint from a person we will make up a file containing the details of the complaint. This will contain the identity of the complainant and any other individuals involved in the complaint. We will only use the Personal Information we collect to process the complaint and to check on the level of service we provide.
We will have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep Personal Information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for three years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
9. How to contact us
The Office Manager
Lead the Way Consulting
38 Braunton Road