Privacy Policy and Data Processing

PRIVACY NOTICE (Data Processing)

Action Potential for Learning (APFL) Ltd.

Who we are and how we process your personal data

Action Potential for Learning (APFL) Ltd. complies with their obligations under the General Data Protection Regulation (GDPR) by keeping personal data up to date; by storing (and destroying it) securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

We use your personal data for the following purposes

To deliver the services that clients have requested;

To contact my clients as necessary in accordance with the services they have requested;

To maintain my own accounts and records.

N.B. If any recorded data is used for research purposes, my own supervision or for the instruction or tuition of students, all such data will be sufficiently anonymised to the extent that individual clients cannot be identified. Should a client indicate that their data should not be used for these purposes, I would refrain from using that data.

Individual client data will never be passed to anyone else without your consent as the client. However, confidentiality may be broken if my own safety or that of you the client, the client’s family members or other members of the public is at risk, or if I am required by law to do so.

In accordance with my need to maintain the possibility of access to client data because of returning clients or those who may wish to lodge a complaint in respect of professional services to either my professional body or my insurers (i.e. in all cases perhaps after a long period of time has elapsed), I retain client data for a minimum period of 7 years. For clients under the age of 18, data will be retained until their 25th birthday. The information will be shredded and deleted.

My Lawful Basis for processing client personal data

The client has given clear consent for me Action Potential for Learning (APFL) Ltd. to process their personal data for a specific purpose. Further, the processing is necessary for both my client’s and my own legitimate interests.

Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

The right to request a copy of your personal data which the I hold about you;

The right to request that I correct any personal data if it is found to be inaccurate or out of date;

The right to request your personal data is erased where it is no longer necessary for me to retain such data;

The right to withdraw your consent to the processing at any time;

The right to request that I, (the data controller) provide you (data subject), with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [N.B. This only applies where the processing is by your consent or is necessary for the performance of a contract and if this is the case, the data will be sent by automated means].

The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

The right to object to the processing of personal data, (where applicable) [N.B. This only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics]

The right to lodge a complaint with the Information Commissioners Office. (See below).

Complaints Notice

The client has the right to complain to the Independent Commissioner’s Office (ICO) if they think there is a problem with the way I am handling their data

(see https://ico.org.uk/concerns/handling/).

PDF version.