Data Handling
1. Why should you read this document?
When working with Liberating Brilliance, we will ask you to provide us with detailed personal information relating to your contact details, health, fitness, training, and injury history and possibly family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.
2. What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date of birth, or address. Your Personal Data may also identify you indirectly, for example, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
Your Personal Data may include:
Title, name, date of birth, gender, nationality, civil/marital status, contact details and addresses
Health, injury, and fitness status, details of treatments, assessments, and prognosis, medications, medical reports, training programmes, and test results (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
3. The basis upon which Liberating Brilliance deals with Your Personal Data
When we speak with you about your support from Liberating Brilliance, we do so on the basis that both parties are entering a contract for the supply of services. In order to perform that contract, and to arrange the appropriate service you require, we have the right to use Your Personal Data for the purposes detailed below.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided in a legitimate business interest to do so and your rights are not affected. For example, we are required to store Your Personal Data in relation to your health, fitness, and injury status for a period of 6 years to comply with industry legislation and regulatory obligations.
4. How do we collect Your Personal Data?
We will collect and record Your Personal Data mainly directly from you. You will usually provide information during the course of our initial meetings or conversations, and assessments with you to establish your circumstances and needs. You will provide information to us verbally and in writing, including email.
We may also collect your Personal Data from individuals who work within your performance support team or those who consult with you and your performance support team (those identified in section 6).
5. What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
Record and store Your Personal Data in our paper files, mobile devices and on our computer systems. This information can only be accessed by employees and consultants within our business and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
Use Your Personal Data for the purposes of responding to any queries you may have in relation to your service.
6. Sharing Your Personal Data
To provide you with an effective service, we will be required to share your Personal Data to:
Identified individuals who work within your performance support team (e.g., coaches, doctors, physiotherapists, nutritionists, and analysts)
Identified individuals who consult with you or your performance support team (e.g., individuals or businesses who provide ad hoc support)
Third parties who we believe will be able to assist us with suppling the service (in each case where we believe this to be required due to your particular circumstances e.g., subject matter experts which are partners to Liberating Brilliance).
At the end of this document, you have the option to agree to allow us to share your Personal Data with those listed above.
Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages. We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.
7. Security and retention of Your Personal Data
Your privacy is important to us, and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either electronically or in paper form for a minimum period of 6 years following the advice/service you receive from us, although your data could be held for a longer period where this may be needed to meet the requirements of our regulatory bodies.
8. Your rights in relation to Your Personal Data
You can:
request copies of Your Personal Data that is under our control
ask us to further explain how we use Your Personal Data
ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
ask us to send an electronic copy of Your Personal Data to another organisation should you wish
change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)
9. How to make contact with Liberating Brilliance in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:
Alex Wolf: Alex@Liberating-Brilliance.com
If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time. You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
You can download a copy of this Data Handling Policy for your records here