Direct Users’ Privacy Notice

At Sixth Sense Consulting Limited, we take the issue of privacy extremely seriously.  This privacy policy explains what information is received about you – from you and/ or others and how we use the information that we have collated.

It is important that you read this privacy notice together with any other notices (either privacy notices or fair processing notices) we may provide you on specific occasions when we are collecting or processing personal information about you, so that you are fully aware of how and why we are using your information.  This privacy notice supplements the other notices and is not intended to override them.

Sixth Sense Consulting Limited is the information controller and is responsible for your personal information (“Sixth Sense”, “we”, “us” or “our” in this privacy notice).  We are registered with the Information Commissioner’s Office (registration number ZA092045).   Our contact details are available on the last page of this document should you need them.

What information do we receive or collect about you?
How long do we keep information about you?
Where does your information come from?
How will we use the information about you?
How to withdraw your consent
If you fail to provide personal data
Sharing information about you with others
Your rights
Data security
Changes to our privacy policy
How to contact us

What information do we receive or collect about you?

The following table shows what personal information we may receive or collect about you depending on the services we are providing: 

_{*Your Identity Data includes first name, last name, telephone number(s), email address, home address and email address.}

We may also collect, use and share statistics based on the information collected.  Statistics are not considered personal information in law as they do not directly or indirectly reveal your identity.  For example, we may create statistics on the number of individuals who seek our support . However, where you can still be identified, whether directly or indirectly, as a result of the statistic being combined with your personal information, this privacy policy will apply.

Considering the services we offer, it is likely we will process special types of data** about you.  Special types of data includes details about your ethnicity or race, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric information.   We however do not anticipate we will collect information about criminal convictions and offences.

How long do we keep information about you?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for the personal data, we consider the applicable legal requirements, the amount of personal data, the nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means.

Details of retention period for different aspects of your personal data are available in our retention policy which you can request from us.

As a guideline, our aim is to delete the majority of information about you after two years following the end of the coaching, psychotherapy or counselling services, unless there are sound reasons for retaining it for longer.   We will, however, keep a record of your name and summary notes on the services provided for seven years following the end of the coaching, psychotherapy or counselling services (unless there are sound reasons for retaining them for longer).

Where does your information come from? 

We will mainly obtain information directly from you.  Where we need information from others, such as where we wish to obtain 360 feedback data or the opinion of others about your performance and approach, we will discuss this with you.  We may need to arrange for a psychometric test, in which case we will refer you to one of our trusted psychometric test provider who will send you a test to complete then will send the results to us directly.

How will we use the information about you?  

We will only use your Information when the law allows us to. Most commonly, we will process personal information collected from you or others about you as it is necessary in order to enter into a contract or to provide our services to you in accordance with the terms of our agreement and/or to protect our legitimate interests or those of others (such as your GP). A legitimate interest is when we have a business or commercial reason to use your information. However, it must not unfairly go against what is right and best for you.

Where we process special types of data (includes details about your ethnicity or race, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric information) and/or information about criminal convictions and offences, we will, in addition, rely either on your explicit consent or on the fact that processing is necessary in relation to legal proceedings.

In very rare circumstances, we may also be required to process your personal data when it is necessary in order to protect your vital interests or the vital interests of another person. This might happen where the information is of such gravity that confidentiality cannot be maintained; for example where we have reasonable grounds to believe that you are about to harm yourself and/or others.  Where we need to disclose sensitive data about you as a result, we will also either rely on your consent or where we cannot obtain it, we will consider your vital interests or the vital interests of another person.

Where we are required by law to process your data, we will do so on the basis that a legal obligation makes the processing necessary.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please let us know. All relevant contact details are available at the end of this document.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How to withdraw your consent  

You have the right to withdraw consent at any time. Please contact us if you want to do so. All relevant contact details are available at the end of this document.

If you withdraw your consent, we may not be able to provide certain products or services. If this is so, we will inform you.

If you fail to provide personal data 

The quality of our services depend on information you share with us.  Where you fail to provide information about you that is relevant, this may affected the services we provide.

Sharing information about you with others  

Sixth Sense contracts with consultants who are, by profession, psychologists, coaches, counsellors or psychotherapists in order to deliver its services.  Consultants have to go through a thorough selection process before being trusted to join the Sixth Sense team. Our consultants are subject to rigorous obligations with regard to privacy and data protection. Our Consultants and project managers might assist us with the delivery of our services.

Sixth Sense Consulting Limited also works with third parties who provide services which include:

• Psychometric test providers (where we are arranging for you to complete a test);
• IT consulting services;
• Email campaign facilitator (if you wish to be added to our contact list); and
• other administrative and back-up and security services.

Where we need to transfer your personal information outside the EU we will make sure that it is protected in the same way as if it was being used within the EU. We will use one of these safeguards:

• Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
• Put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website,
• Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website.

Your rights 

The following rights are available to you:

1. Access: You have the right to request a copy of the information that we hold about you.
2. Correction: We want to make sure that your personal information is accurate and up to date. You may ask us to check and correct information you think is inaccurate.
3. Erasure: You have the right to ask us to delete or remove personal information where there is no good reason for us continuing to process it and/or where you have exercised your right to object to processing (see below).
4. Object to processing: This relates to situations 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
5. Restriction of processing: You have the right to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
6. Transfer: You have the right to request the transfer of your personal information to another party.
7. Automated decision-making (including profiling): you will not be subject to decisions that will have a significant impact on you based solely on automated decision-making (including profiling), unless we have a lawful basis for doing so and we have notified you.  In the unlikely event you are notified that decisions are made without any human involvement or we subject you to profiling, you will have the right to challenge the decision, express your point of view and request for human intervention.

Please note that there may be some reasons why we need to keep and use your personal information which mean that we might not be in a position to respond favourably to every request. You should however let us know if you think we should not be using your personal information and we will review.  If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please email us on Chris.Welford@sixthsenseconsulting.co.uk clarifying your request(s).

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 or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

In order to consider your request, we may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

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.

Data security  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, associates, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and Information Commissioner’s Office of a breach where we are legally required to do so.

Changes to our privacy policy 

We keep our privacy policy under regular review. This privacy policy was last updated on 21 March 2018.

We may also notify you in other ways from time to time about the processing of your personal information.

How to contact us 

The Directors for Sixth Sense are responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below:

• by email: Chris.Welford@sixthsenseconsulting.co.uk
• by phone: 0800 048 8615
• or write to us at: Chris Welford, Sixth Sense Consulting Limited , 22 Village Square, The Bramhall Centre Bramhall, Stockport, Cheshire, SK7 1AW

You have the right to make a complaint at any time to the Information Commissioner’s office (ICO), the UK supervisory authority on data protection (https://ico.org.uk/concerns/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.