RICE CONSULTANCY LIMITED
Privacy Notices
TABLE OF CONTENTS
If you are a coachee, supervisee, trainee or person enquiring about our services via our website, please click here, and
if you are a corporate client or business contact, please click here.
PRIVACY NOTICE FOR COACHEES, SUPERVISEES, TRAINEES AND THOSE WHO ENQUIRE ABOUT OUR SERVICES VIA OUR WEBSITE
This privacy notice describes how Rice Consultancy Limited (Rice Consultancy or we/us) uses personal data relating to our coachees, supervisees and trainees, and those who enquire about coaching or supervision via our website. It also describes how Associates of Rice Consultancy use coachee and trainee data.
We may update this notice from time to time. It was last updated on 13th January 2022.
This notice is set out in the following sections.
1. THE QUICK READ
Controller – Rice Consultancy: Rice Consultancy is a controller for use of your personal data, meaning it decides how and why your personal data is used. You can contact us at: office@riceconsultancy.com.
Controller – Associate: If you are a coachee or trainee who is coached or trained by one of our Associates, the Associate will also be an independent controller of your personal data for the purposes of the coaching or training sessions. At the date of this notice, the Associates are Claire Lea and Liz Cox.
Coachees and supervisees: We may obtain your name, contact details and relevant background information from your organisation or from you directly. We, or the relevant Associate, will use your personal data to provide the coaching, training or supervision services. This includes notes made of the sessions with you, and other notes and communications relevant to these sessions. These may include sensitive information discussed during the sessions, such as data about your health, or racial or ethnic origin.
Sharing notes of sessions: Neither we nor our Associates share personal data discussed in coaching or supervision sessions with your organisation or any other parties, except with your consent or in exceptional circumstances. Exceptional circumstances include where required by law, in order to protect you or someone else, or to protect our legal rights.
Coachees and supervisees – additional records: Rice Consultancy will also hold information about you in order to keep records relevant to our relationship with your organisation (or you if you engage us directly) and our Associates. This includes your name, dates and times of sessions, payment information, and related communications. This information may be shared with your organisation.
Trainees: We may hold your name and a record that you attended (or were due to attend) a relevant training session, and other business information about you. We obtain information from your organisation who requested the training (or its website), and from other public forums such as LinkedIn. We do not generally create additional records about trainees.
Retention of data: We and our Associates generally retain notes of our coaching and supervision sessions for 1 year. We generally retain other records containing your personal data for up to 7 years.
Our service providers: Our service providers, including technology providers, may hold your data on our behalf (as processors) in providing their services to us.
International data transfers: We do not generally transfer your data outside the UK, except where you are outside the UK, or your organisation (or its head office) is located outside the UK, or to the extent our service providers have data centres outside the UK.
Your rights: You have rights in relation to our use of your data, including the right to access a copy of the data we hold about you, to withdraw any consent you have given, and, in certain circumstances, to object to our use of your data or request that we erase your data.
2. WHO WE ARE, WHO OUR ASSOCIATES ARE
2.1 Rice Consultancy Limited
Rice Consultancy Limited is a company registered in England and Wales, with company number 11871530, and registered office at 1 Lingfield Road, London, SW19 4QA. For the purposes of data protection law, Rice Consultancy acts as a controller in our use of your personal data, meaning that we decide how and why we use your data.
You may contact Rice Consultancy with any queries or concerns about our use of your personal data, and to exercise your data protection rights, using the following contact details.
Email: office@riceconsultancy.com
2.2. Associate – Claire Lea
Claire Lea is an Associate for Rice Consultancy, who provides coaching and training services. For the purposes of data protection law, Claire acts as an independent controller in her use of your personal data for providing coaching and training services.
You may contact Claire with any queries or concerns about her use of your personal data, and to exercise your data protection rights, using the following contact details.
Email: claire@riceconsultancy.com
2.3 Associate – Liz Cox
Liz Cox is an Associate for Rice Consultancy, who provides coaching and training services. For the purposes of data protection law, Liz acts as an independent controller in her use of your personal data for providing coaching and training services.
You may contact Liz with any queries or concerns about her use of your personal data, and to exercise your data protection rights, using the following contact details.
Email: liz@riceconsultancy.com
3. USE OF DATA ABOUT OUR COACHEES AND SUPERVISEES
3.1 Referral from your organisation
You may be referred to us for coaching or supervision by your organisation, in which case your organisation will provide us with your name, job title, contact details, and background information about you and relevant to the coaching or supervision sessions.
If you are allocated to one of our Associates for coaching, we will share this information with that Associate. We, or our Associate, may then contact you to make arrangements for the sessions. your organisation may also share background information directly with our Associate.
Our and our Associate's legal basis under data protection law for using your data is that it is necessary in our and their legitimate interests in providing the relevant coaching or supervision services.
3.2 Engaging us directly
If you engage Rice Consultancy directly for coaching or supervision services, we will collect information from you to provide these services, including your name, contact details, and background information relevant to the coaching or supervision sessions.
If you are allocated to one of our Associates for coaching, we will share this information with that Associate, who may then contact you directly to make arrangements for the sessions.
Our legal basis under data protection law for using your data is that it is necessary for performing our services contract with you (or to take steps requested by you prior to entering into the contract). Our Associate's legal basis is that it is necessary in their legitimate interests in providing the relevant coaching or services.
3.3 Coaching and supervision sessions
We or the Associate may make notes of your coaching or supervision sessions. This includes notes of matters discussed during the sessions, and other notes relevant to the sessions, such as themes and goals. They may include notes about sensitive matters which are discussed, such as information about your health, ethnic origin, beliefs or relationships with other people. We or the Associate will also have records of any related emails or communications with you.
These notes and records assist us and our Associates to provide our services effectively, and to ensure continuity between sessions, and they may be stored in paper or electronic form.
Note that our Associate will not generally share notes of coaching sessions with Rice Consultancy. In addition, notes of coaching and supervision sessions will not generally be shared with your organisation. See also section 6.
Our and our Associate's legal basis under data protection law for using your data is that it is necessary in our legitimate interests in providing coaching and supervision services (or, if you engage us directly, that it is necessary for performance of our contract with you). We shall also seek your consent to making notes of any 'special categories of data' or data relating to criminal offences or convictions. Note: under data protection law, 'special categories of data' means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; genetic data, biometric data used for uniquely identifying you, and personal data concerning health, sex life or sexual orientation.
3.4 Accounts and records
Rice Consultancy will also hold information about you to keep accounts and records relevant to our relationships with your organisation (or with you, if you engage us directly), and with our Associate (if they are coaching or training you). This information includes your name, dates and times of sessions and your attendance (which we may obtain from our Associate), associated payments, and other communications between us and your organisation, you or our Associate relating to the coaching, training or supervision arrangements. This information may be shared with your organisation and, if requested by your organisation, with the organisation's head office (or other related entity) which is involved in the coaching, training or supervision arrangements.
Our legal basis under data protection law for using and sharing this data is primarily that it is necessary in our legitimate interests in managing our relationships with your organisation (or with you if you engage us directly) and with our Associates. To the extent we share this data with your organisation's head office (or other related entity), our legal basis is that it is in the legitimate interests of your organisation in administering the coaching, training and supervision arrangements.
3.5 Other uses of your data
Your personal data may also be used by us and our Associates to protect or enforce legal rights, or for other purposes permitted or required by law, including data protection law (in our or our Associates' legitimate interests, or as needed to comply with a legal obligation).
4. USE OF DATA ABOUT OUR TRAINEES
When we provide training services, your organisation will provide us with a list of trainees who are due to attend the sessions. As well as your name, your organisation may provide us with additional information relevant to the training, such as your job title and PQE level. We may also look at your business or professional bio or profile on your organisation's website or within other public forums, such as LinkedIn. This additional information assists us to tailor our training sessions. We may also hold a record that you attended the relevant training sessions. Our legal basis under data protection law for keeping these records is that it is necessary in our legitimate interests in providing training services.
We do not generally create additional records about trainees.
Your personal data may also be used by us to protect or enforce legal rights, or for other purposes permitted or required by law, including data protection law (in our legitimate interests, or as needed to comply with a legal obligation).
5. USE OF YOUR DATA IF YOU COMPLETE OUR WEBSITE CONTACT FORM
If you contact us using our website contact form, we will use the information you provide to get in touch with you and respond to your query, and to keep appropriate records of enquiries (in our legitimate interests). If you are interested in receiving coaching or supervision services directly from us, we may request additional information about you and the services you are looking for, to arrange these services. See section 3.2.
6. SHARING YOUR DATA
6.1 Associates
Where one of our Associates is providing your coaching or training sessions, Rice Consultancy may share your data with the Associate, in our and their legitimate interests in providing the coaching or training services.
Our Associates will not generally share notes of coaching or training sessions with Rice Consultancy (see section 3.3), except with your consent or in exceptional circumstances – see section 6.4. However, they may share with us other information about the sessions (such as your attendance and the dates and times) (see section 3.4).
6.2 Your Organisation
Relevant information about your coaching, supervision or training sessions (such as your attendance, and the dates and times) may be shared with your organisation who instructed us in relation to our services, and, in some cases, with its head office (see section 3.4).
Notes of coaching and supervision sessions will not generally be shared with your organisation (see section 3.3), except with your consent or in exceptional circumstances – see section 6.4.
6.3 Service providers
Our and our Associates' service providers may handle your data, such as providers of email, document management and accounting systems. They act as processors on our and our Associates' behalf, meaning that we and our Associates remain primarily responsible for how they use your data on our behalf in line with the purposes and legal bases identified in sections 3 to 5.
Each of our Associates uses a Rice Consultancy email address. Rice Consultancy has the relationship with the email provider. However, Rice Consultancy does not seek to access emails sent or received by its Associates using their Rice Consultancy email addresses.
6.4 Other sharing of data
We and our Associates may also share relevant personal data with the following parties:
legal authorities or regulatory bodies, our legal or professional advisers or auditors, or other parties where we or our Associates are required by law to do so (for compliance with a legal obligation, or otherwise in legitimate interests to protect or enforce our or their rights);
prospective or actual purchasers of our or our Associates' company or business (in their legitimate interests);
other parties with your consent (for example if you give your consent to share certain notes of sessions with your organisation); and
other parties where necessary to protect your rights and interests, or the rights or interests of another individual (in our legitimate interests, or for compliance with a legal obligation).
7. INTERNATIONAL DATA TRANSFERS
We and our Associates do not generally transfer your data outside the UK except:
where you are located outside the UK, in which case we or they may transfer data in communications with you; or
where your organisation, or its head office (or other related entity) is located outside the UK. We may transfer information such as your name, and dates and times of sessions, as described in section 3.4. Some countries or jurisdictions (such as the European Union) are covered by UK adequacy regulations, meaning that their data protection law is similar to that in the UK. If the country of transfer is not covered by UK adequacy regulations, we shall seek your consent to making such a transfer; or
where our or their service providers have data centres or systems outside the UK.
8. RETAINING YOUR INFORMATION
We and our Associates will retain your personal data for as long as we need it for the relevant purposes specified above, in accordance with our records retention procedures.
For coachees and supervisees:
notes of sessions (see section 3.3) are generally retained for 1 year from the conclusion of the coaching or supervision programme; and
other records relating to sessions (see section 3.4) are generally retained for 7 years or such other period as we may have agreed with any relevant service providers.
Our retention periods may be changed in appropriate circumstances, for example we may need to retain your details for longer if there is a relevant dispute or potential dispute.
Please contact us or our Associates (using the contact details at section 2) for additional information about retention periods and procedures.
9. YOUR DATA PROTECTION RIGHTS
Under data protection laws, you have certain rights in relation to our and our Associates' use of your personal data. These rights include the following:
to obtain a copy of the personal data held about you, together with other information about how we and our Associates use it (known as a subject access request);
to withdraw any consent which you have given relating to the use of your data;
to request rectification of inaccurate or incomplete data, and, in some circumstances, to request us or our Associates to erase or restrict our use of your data;
where the legal basis for use of your data is legitimate interests (as specified in sections 3 to 6), to object to our or our Associates' processing of your data for reasons relating to your particular situation;
to object to the use of your data for direct marketing purposes;
where the legal basis for use of your data is your consent or necessity for our contract with you (as specified in sections 3 to 6), to exercise a right to data portability, in order to transfer sets of data provided by you and held electronically to another organisation; and
not to be subject to a decision based solely on automated processing, which significantly affects you, unless additional legal requirements are met (although neither we nor our Associates make any such decisions as at the date of this notice).
Please contact Rice Consultancy or the relevant Associate (see section 2) to send requests to exercise your rights (specifying what you are requesting), or if you would like additional information about your rights. Note that there are certain limitations and exemptions to these rights which we and our Associates may apply depending on the circumstances.
You may also make a complaint about how we or our Associates handle your data to the UK Information Commissioner's Office. Please visit ico.org.uk for further information about how to do this (and further guidance on your rights). You may also take legal action in court to enforce your rights.
PRIVACY NOTICE FOR CORPORATE CLIENTS AND BUSINESS CONTACTS
Rice Consultancy Limited (Rice Consultancy or we/us) provides coaching, supervision and training services. Our corporate clients may request these services for their staff or other individuals. This privacy notice describes how we use personal data relating to our client contacts, and to our other business contacts (you). It also provides information for clients about data protection issues when providing us with data about individuals who will receive our services.
If you are a coachee, supervisee or trainee, please refer to our separate privacy notice available here.
We may update this notice from time to time. It was last updated on 13 January 2022.
This notice is set out in the following sections.
1. THE QUICK READ
Controller: Rice Consultancy is a controller for use of your personal data, meaning it decides how and why your personal data is used. You can contact us at: office@riceconsultancy.com.
Use of client data: We hold personal data relating to our contacts within client organisations in order to provide our services and manage our relationship with our clients. This includes names, contact details and roles. We may also obtain information from public sources such as Companies House and LinkedIn. We may share relevant data with our Associates who are involved in providing some of our coaching and training services.
Client responsibilities: If you represent a client and provide information to us about coachees, supervisees or trainees, please ensure compliance with data protection rules, including letting individuals know you are sharing data with us, and only providing us with information relevant to our services.
Business contacts: We hold personal data relating to contacts at our suppliers and other organisations with whom we have a business relationship. This includes names, contact details, and roles.
Enquirers and visitors: If you send us an enquiry or visit our organisation, we may hold information about you as relevant to your enquiry or visit.
Sharing with our Associates: If you are a client or supplier contact, we may share your contact details with our Associates who assist us to provide our coaching and training services.
Sharing with our service providers: Our service providers, including technology providers, may hold your data on our behalf (as processors) in providing their services to us.
International data transfers: We do not generally transfer your data outside the UK, except where you or the organisation for whom you work are located outside the UK, or to the extent our service providers have data centres outside the UK.
Your rights: You have rights in relation to our use of your data, including the right to access a copy of the data we hold about you and, in certain circumstances, to object to our use of your data or request that we erase your data.
2. WHO WE ARE
Rice Consultancy Limited is a company registered in England and Wales, with company number 11871530, and registered office at 1 Lingfield Road, London, SW19 4QA. For the purposes of data protection law, Rice Consultancy acts as a controller in its use of your personal data, meaning that we decide how and why we use your data.
You may contact Rice Consultancy with any queries or concerns about our use of your personal data, and to exercise your data protection rights: office@riceconsultancy.com.
3. CLIENTS
3.1 Data we hold about clients
We hold personal data relating to our contacts within client organisations (and their head office or related entities). These contacts may include individuals who requested or sponsor our services, who provide us with background information for our services, or who are otherwise involved in the relationship between us and our client.
The personal data we hold typically includes: names, contact details and roles within the organisation. It may also include other personal data which is discussed in meetings or communications relating to our services. We use this information to provide our services and manage our relationship with our client.
We may also obtain some information about our clients and related individuals from public sources. This may include, for example, information available at Companies House, or details published on LinkedIn or other social media platforms. This assists us to understand our clients and their needs, as relevant to the services we provide.
Our legal basis under data protection law for using your data in this way is that it is necessary in our legitimate interests in providing our services to our client.
3.2 Data about coachees, supervisees and trainees
Personal data you share with us
Our clients may request us to provide our services to specified individuals. You (representing our client), may provide us with personal data about these individuals. This typically includes: names, job titles, contact details and other background information about them.
Please ensure that disclosure of this personal data to us is done in compliance with data protection requirements. In particular, you should:
ensure the individuals are aware that their details are being disclosed to us for the purpose of our services; and
only share with us background information which is relevant for this purpose.
Note that we may pass on relevant information about an individual to one of our Associates if they are involved in providing the services to that individual.
Personal data collected by us
We will collect information about coachees, supervisees and trainees during the course of providing our services. We process this personal data in accordance with our coachee, supervisee and trainee privacy notice available here
Please respect the confidentiality of matters that are discussed in our coaching and supervision sessions. We will not generally share notes of these sessions with our clients, except in exceptional circumstances (such as where required by law).
Other information about our sessions (such as attendance, dates and times) may be shared with you for managing our relationship with our client, including for billing purposes. Please ensure your use of this data complies with data protection requirements.
4. OTHER BUSINESS CONTACTS
We hold personal data relating to:
contacts at our suppliers and other organisations with whom we have a business relationship; and
enquirers or visitors to our business.
This personal data typically includes: names, contact details, roles, information relating to the enquiry or visit, and any other personal data discussed within communications with you or your organisation. If you are self-employed or a sole trader, it may also include finance and billing details, and other information relating to your business.
We use these details for business reasons consistent with the relevant matter, including: to manage our relationship with you and your organisation, to respond to your enquiries, or to manage the goods or services you provide.
We may also obtain some information about you from public sources. This may include, for example, information available at Companies House, or details published on LinkedIn or other social media platforms. This assists us to understand your business or your needs, as relevant to our relationship with you or your organisation.
Our legal basis under data protection law for using your personal data is our legitimate interests in carrying out these activities or, if we have a contract with you as a self-employed individual or sole trader, necessity for performance of this contract.
If you are enquiring about receiving our coaching, supervision or training services directly from us, please also read our coachee, supervisee and trainee privacy notice available here.
5. USE OF YOUR DATA FOR RECORD-KEEPING AND LEGAL MATTERS
Your personal data may also be used by us:
to maintain appropriate records of our business communications and relationships (in our legitimate interests); and
to protect or enforce legal rights, or for other purposes permitted or required by law, including data protection law (in our legitimate interests, or as needed to comply with a legal obligation).
6. SHARING YOUR DATA
6.1 Associates
If you are a client contact: Rice Consultancy works with Associates who provide coaching and training services. Our Associates may be involved in coaching or training individuals referred to us by our client. In such cases, we may provide our Associates with your details, so that they can discuss the background to the services and the individuals directly with you.
Our legal basis for sharing your data is our and our Associates' legitimate interests in providing the coaching or training services.
If you are a supplier contact: Rice Consultancy may share your details with our Associates if they need to use your services as part of their activities for Rice Consultancy (such as their use of our technology systems).
Our legal basis for sharing your data is our and our Associates' legitimate interests in receiving the services which you provide.
As at the date of this notice, our Associates are Claire Lea (claire@riceconsultancy.com) and Liz Cox (liz@riceconsultancy.com). Each Associate acts as an independent data controller in their use of your data.
6.2 Your organisation
Relevant information about you may be shared within your organisation. For example, if you are our contact within a client organisation, we may refer to you within communications with our client.
If you are a client contact: Your name and contact details may be shared with relevant coachees, trainees or supervisees, for example if they query how we obtained their details.
6.3 Service providers
Our service providers may handle your data, such as providers of technology services, and our email, document management and accounting systems. They act as processors on our behalf, meaning that we remain primarily responsible for how they use your data on our behalf in line with the purposes and legal bases identified in sections 3 to 5.
6.4 Other sharing of data
We may also share relevant personal data with:
legal authorities or regulatory bodies, our legal or professional advisers or auditors, or other parties where we are required by law to do so (for compliance with a legal obligation, or otherwise in our legitimate interests to protect or enforce our rights);
prospective or actual purchasers of our company or business (in their legitimate interests); and
other parties where necessary to protect your rights and interests, or the rights or interests of another individual (in our legitimate interests, or for compliance with a legal obligation).
7. INTERNATIONAL DATA TRANSFERS
We do not generally transfer your data outside the UK except:
where you or the organisation for whom you work (for example our corporate client or supplier) or its head office (or other related entity) are located outside the UK, in which case we may transfer data in communications with you or the relevant organisation; or
where our service providers have data centres or systems outside the UK.
8. RETAINING YOUR INFORMATION
We will retain your personal data for as long as we need it for the relevant purposes specified above, in accordance with our records retention procedures. Our retention periods may be changed in appropriate circumstances, for example we may need to retain your details for longer if there is a dispute or potential dispute relevant to our relationship with you.
Please contact us (using the contact details at section 2) for additional information about our retention periods and procedures.
9. YOUR DATA PROTECTION RIGHTS
Under data protection laws, you have certain rights in relation to our use of your personal data. These rights include the following:
to obtain a copy of the personal data held about you, together with other information about how we use it (known as a subject access request);
to withdraw any consent which you have given relating to the use of your data;
to request rectification of inaccurate or incomplete data, and, in some circumstances, to request us to erase or restrict our use of your data;
where the legal basis for use of your data is legitimate interests (as specified in sections 3 to 6), to object to our processing of your data for reasons relating to your particular situation;
to object to the use of your data for direct marketing purposes (though, as at the date of this notice, we do not generally use your data for these purposes);
where the legal basis for use of your data is your consent or necessity for our contract with you (as specified in sections 3 to 6), to exercise a right to data portability, in order to transfer sets of data provided by you and held electronically to another organisation; and
not to be subject to a decision based solely on automated processing, which significantly affects you, unless additional legal requirements are met (although, as at the date of this notice, we do not make any such decisions).
Please contact Rice Consultancy (see section 2) to send requests to exercise your rights (specifying what you are requesting), or if you would like additional information about your rights. Note that there are certain limitations and exemptions to these rights which we may apply depending on the circumstances.
You may also make a complaint about how we handle your data to the UK Information Commissioner's Office. Please visit ico.org.uk for further information about how to do this (and further guidance on your rights). You may also take legal action in court to enforce your rights.