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Privacy Policy

Privacy notice for


Purpose of privacy notice

The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation will replace current data privacy law, giving more rights to you as an individual and more obligations to the organisation holding your personal data.
This new privacy notice as in effect from 25 May 2018.

Who is is the data controller ( Heather Fitton.) This means I decide how your personal data is processed and for what purposes.


Whose information does this privacy notice apply to?

This privacy notice applies to information I collect from:

  • clients
  • prospective clients
  • former clients
  • people who subscribe to my newsletter;
  • visitors to the website


What is personal data?

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data I may hold about you include your contact and appointment details.

Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data I may hold about you include your client notes.


How do I process your personal data?

I comply with obligations under the 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. I use your personal data for the purposes set out below.

Sections 1 – 15 apply to clients, prospective clients, former clients and visitors to the Ch-changes website and coaching space offered at 40.Cromford Rd Wirksworth DE4 4FR for local clients.

I use your name, address, telephone number and email address to make and rearrange appointments. I am unable to send or receive encrypted emails so you should be aware that any emails I send or receive may not be protected in transit. I will also monitor any emails sent to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send to me is within the bounds of the law.

I keep a permanent attendance register which records all appointments for clients who both attend the coaching hub and who coach with me online.I also keep a record of when you were coached by me for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint.

I may use your date of birth to help identify clients with the same name to avoid mistakes being made as to safe and appropriate identification purposes if referring a client to another practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the client.

I use your presenting issue and the circumstances reported by you for the purposes of making an appropriate coaching intervention for your assistance only.

I use any relevant medical and family history you have told me for making an appropriate coaching intervention only.

It is not essential that you supply me with the name of G.P. but you may wish to. I only communicate with your G.P. with your expressed knowledge and consent.

I keep a record of and refer to that record of any coaching you undertake with me and details of progress of your case, including planning and reviews of coaching intervention: This would need to be made available as evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.

I record any decisions made in conjunction with you to help you to receive the most appropriate coaching and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.

I keep accident records for any coachees, visitors or staff who are involved in accidents at the coaching hub in accordance with UK Health and Safety legislation including the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to comply with the law and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.

In the event of an adverse incident occurring to any of my clients I report the matter to the insurance company to enable any potential claims to be dealt with.

Where relevant I maintain records of the client’s consent to coaching, or the consent of their next-of-kin in order to be able to prove that the client (and/or parent/guardian/next of kin) has given informed consent to coaching to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint.

Section 16 applies to those who complain about our services

When I receive a complaint from a client I make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint .This file will be kept in a locked filing cabinet.

I will only use the personal information I collect to process the complaint and to check on the level of service I provide. I usually have to disclose the complainant’s identity to whoever the complaint is about. If a complainant doesn’t want information identifying him or her to be disclosed, I will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. I may need to further process personal information collected in relation to acomplaint.

I will keep personal information contained in complaint files in line with my retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

Similarly, where enquiries are submitted to me ,I will only use the information supplied to deal with the enquiry and any subsequent issues and to check on the level of service I provide.

Sections 17 and 18 apply to subscribers to my newsletters

I maintain and use records of subscribers to my newsletters, only with their consent, for marketing purposes. This is kept on my computer system.

Sections 19 – 23 apply to the website users

When someone visits my website, I use a third -party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is processed in a way which does not identify anyone I do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If I do want to collect personally identifiable information through the website, I will make it clear when I collect personal information and will explain what I intend to do with it.
I use a third party service (The Good Alliance) to help maintain the security and performance of my website. To deliver this service it processes the IP addresses of visitors to my website.
I use a standard WordPress website to collect anonymous information about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it.


How long do I keep your personal data?

I keep your personal data for no longer than reasonably necessary.

I keep clients records for a period of 7 years in compliance with DP legislation

Data will be reviewed annually and any records that are no longer relevant will be destroyed (shredded). Also, in the event that I am unable to work due to illness or death, records will be confidentially destroyed, unless there is any request to transfer it to another practitioner.

At any time, you may request that changes are made to your contact details.


Your rights and your personal data

Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.

The right to request a copy of your personal data which 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. This right does not apply where I am processing information using a lawful purpose other than consent.

The right to request that I provide you 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) [This right only applies where the processing is based on consent or is necessary for the performance of a contract with you and in either case I am processing the data 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) [This right 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 be informed if your data is lost. We shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.

The right to lodge a complaint with the Information Commissioner’s Office.
For further details about these rights please see the Information Commissioner’s website at


Further processing

If I wish to use your personal data for a new purpose, not covered by this Privacy Notice, then I will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, I will seek your prior consent to the new processing.


Contact details

To exercise all relevant rights, queries of complaints please in the first instance contact me
Heather Fitton – 07989 164 585 –
You can contact the Information Commissioners Office on 0303 123 1113 or via email or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF


Heather Fitton is a fully qualified One of Many life coach who works with women who are seeking to transform their personal and professional lives. Heather has practiced Traditional Acupuncture for many years.She brings the knowings of energetics and healing from this ancient craft to the service of coaching. 


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