Privacy Notice

Rowan Sage Advisory Ltd provides independent reviews for organisations and coaching for individuals. For the purposes of data protection law, we are the controller of the personal information described in this notice, except for independent reviews, which are explained in section 12.

• Company: Rowan Sage Advisory Ltd, registered in England and Wales, company number 17415833
• Registered office: 71-75, Shelton Street, Covent Garden, London, WC2H 9JQ, UNITED KINGDOM
• ICO registration number: ZC242052
• Contact for data protection matters: JM@Rowansage.co.uk

If you make an enquiry: your name, contact details, organisation and role where relevant, and what you tell us about your enquiry.

If you are a coaching client: your name, contact details, billing details, session dates, the goals we agree, and notes made during and after sessions. You may choose to tell us about your health, including stress or wellbeing. This is special category information, and we handle it only with your explicit consent (see section 3).

If your coaching is arranged by your employer: in addition to the above, the information your employer gives us to set up the coaching, such as your name, contact details, role and any objectives they have agreed with you.

If you are a professional contact or a client organisation: your name, contact details, role and our correspondence with you.

If you visit our website: technical information collected by our website host and any cookies, as described in our cookie notice.

We must have a lawful basis for each way we use personal information. These are set out below.

Where we rely on legitimate interests, those interests are:

• Responding to enquiries: replying to people who contact us about our services, including on behalf of an organisation, and arranging an initial conversation.
• Coaching arranged by an employer: providing coaching that an organisation has commissioned for you, and keeping the records needed to deliver it.
• Running our business: keeping proper records of our work, managing our relationships with clients and professional contacts, and keeping our website and systems secure.
• Protecting our business: keeping records that may be needed to deal with a complaint or to establish, exercise or defend a legal claim.

We have assessed each of these interests against your rights and freedoms before relying on them.

Most of the information we hold comes directly from you. If your coaching is arranged by your employer, some information comes from them, as described in section 2.

We do not sell your information or share it with others for their marketing. We share it only as follows:

• Service providers who hold or process information for us: For example website host, email provider, booking system, cloud storage and accounting software. They act only on our instructions.
• Professional advisers: our accountant, insurer or lawyer, where this is necessary.
• Your employer, if they arranged your coaching: only the information agreed with you at the start of the coaching. The content of your sessions is not shared without your agreement.
• Where the law requires it: for example, where we are legally obliged to disclose information, such as a serious risk of harm.

Some of our service providers store information outside the UK. Where they do, we make sure it is protected, either because the UK has recognised the country as providing an adequate level of protection, or through appropriate safeguards such as the ICO’s International Data Transfer Agreement. In particular, the use of Proton for for email and calendar, documents and online meetings. Other apps include Microsoft OneNote and Zoom.

At the end of these periods, information is securely deleted.

You are not required by law to give us your information. If you become a coaching client, we need your contact details to provide the coaching under our agreement, and without them we cannot provide it.

You have the right to:

• ask for a copy of the information we hold about you
• ask us to correct information that is wrong or incomplete
• ask us to delete your information
• ask us to restrict how we use your information
• ask for information you gave us under a contract or with your consent to be provided in a format that can be transferred to another organisation
• withdraw your consent at any time where we rely on it, which is as easy to do as giving it: contact us at [email address] or use the unsubscribe link in any marketing email

Some rights apply only in certain circumstances. We will respond within one month of receiving your request.

Your right to object

Where we use your information on the basis of legitimate interests, you have the right to object at any time. You also have an absolute right to object to the use of your information for marketing. To object, contact us at Info@Rowansage.co.uk.

We do not make decisions about you based solely on automated processing.

When Rowan Sage Advisory carries out an independent review, it does so on behalf of the organisation that commissioned it. That organisation decides why and how personal information is used in the review and is responsible for it under data protection law. Its own privacy notice explains how your information is used, and questions about it should be directed to that organisation in the first instance.

We hold personal information in secure systems with access limited to those who need it, and we expect our service providers to protect it to the same standard.

Our website uses cookies as described in our cookie notice.

If you are unhappy with how we have handled your personal information, please contact us first at Info@Rowansage.co.uk. We will acknowledge your complaint within 30 days and let you know the outcome.

You can also complain to the Information Commissioner’s Office at any time:

• Website: ico.org.uk/make-a-complaint
• Helpline: 0303 123 1113
• Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

We review this notice regularly and will publish any changes on this page, with the date it was last updated