Keary Harper LLP Privacy Policy
Background
The Keary Harper partnership has operated since 2000; we have a small team of qualified associates. Our core business is coaching individual executives, but we also coach whole teams, including boards. We also conduct organizational surveys as and when appropriate. Our registered office is in central London and we work flexibly between our offices, clients’ premises, and online.
Confidentiality is central to effective coaching and, if you are a coaching client, this will have been defined and agreed at the outset of any work together; we also conform to the Ethics policy of APECS (Association for Professional Executive Coaching and Supervision).
Data Protection legislation
In order to carry out our business we interact with corporate clients sponsoring coaching programmes, suppliers, associates and other organisations and individuals. We are registered with the Information Commissioner’s Office, conform to the existing Act, and aim to comply with the GDPR effective 25 May 2018. Our data protection officer is John Keary.
Data: nature and usage
Much of the personal data we hold is email addresses and phone numbers: this is used in normal communication and, from time to time, to update you on our activities.
If you are a coaching client, we typically take handwritten notes during coaching sessions – with your permission. We are also likely to have email dialogues about aspects of your development. We do not make electronic recordings of meetings, whether face-to-face or online. If we use specific developmental psychometrics or feedback it will be with your positive consent. These are normally provided by 3rd parties who will process your data on our behalf. They have their own privacy policies to which we can direct you.
Data: specifically excluded
Political or religious affiliations; sexual orientation; financial status; health.
Data retention
It has always been our policy to hold onto data for the minimum length of time necessary. In the case of coaching programmes and other confidential development work, we aim to delete or shred records within 6 months of the completion of the work.
We will retain basic contact details such as email addresses longer but will seek your positive confirmation that we may do so. You have the right under the new law to make a request to us at any time to remove personal information of yours from our databases.
Data security
Our computers and associated devices are security-updated regularly, password protected, and we use encryption. We backup electronic data locally, rather than on the Cloud. Physical data is kept securely under lock and key.
Website
Our website is used for information purposes only. It is non-transactional and does not employ cookies to track you.
Audit & Risk Assessment
We carried out an audit of our data resources and an assessment of risk in April 2018.
Updates
We will update our Privacy Policy as appropriate.
Keary Harper LLP, 21 May 2018