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PRIVACY & CONFIDENTIALITY POLICY

Introduction:

This Privacy and Confidentiality focuses on the need to ensure that private information is accessible only to those authorised to have access to it and the need to protect such information from being shared. Privacy and confidentiality are important principles in the work that Eager Cycle Coaching carries out as they impose boundaries on the amount of personal information and data that can be disclosed without consent.


Eager Cycle Coaching is committed to high standards of information security, privacy and transparency whenever these are required. Information and data on customers must be managed and protected in accordance with current data protection standards and the new EU general data protection laws, which came into force in May 2018. Eager Cycle Coaching will always endeavour to comply with all applicable GDPR regulations when processing information and data on clients (and, where applicable, colleagues).


Should clients need to share sensitive and personal information, they will feel more secure, and be able to trust that their privacy is being protected, knowing that Eager Cycle Coaching has confidentiality practices in place.
Anyone working for Eager Cycle Coaching may have access to a range of information regarding trainees that must be kept confidential. Such information will be collected / stored for the sole purposes of Eager Cycle Coaching’s business and solely for trainees’ relationship with Eager Cycle Coaching’s services.


Examples of confidential client information include (this list is not exhaustive):

  • Personal information such as age, contact details, addresses, email addresses and details of next of kin / emergency contacts.

  • The physical or mental health or trainees including any diagnoses.

  • Trainees’ learning conditions including any learning difficulties or learning disabilities.

  • Behavioural characteristics of trainees and any needs in this area.

  • Strategies to assist trainees to manage any additional needs.

  • Medication or treatment information for trainees.

  • Communication issues and any additional needs in this area.

 

Eager Cycle Coaching will receive confidential information through a number of channels including:

  • Information in training / coaching consent forms.

  • Verbally shared information (such as by the learner themselves or through their carer / guardian or organisation) and verbal disclosures of information during training.

  • Written handovers by others involved in trainees’ care or professional setting (such as by human resources departments).


In addition, confidential personal information on other coaches / instructors may be held should  they be working for (or hoping to work for) Eager Cycle Coaching. This may include additional information such as personal addresses or contact details, CVs, references, DBS information, and information relating to professional practice (such as mentoring or peer-review forms or quality assurance reports). 


Privacy and confidentiality protocols:
This policy now sets out a framework for the expectations of anyone working for Eager Cycle Coaching. It will be explained below how all sensitive information or that containing personal information will be held securely and confidentially (usually with lockable locations if not be carried during training). It will be obtained both fairly and efficiently, recorded accurately and reliably and used effectively and ethically. Confidential information will also only be shared appropriately and lawfully.


Storage of paperwork:
Anyone working for Eager Cycle Coaching will be responsible for ensuring the security for all documents containing confidential information about clients or customers wherever and however this may have been come by or have arisen. This covers all communication, paperwork pertaining to clients and information containing client, stakeholder, or personal information on anyone working for Eager Cycle Coaching. During training sessions, coaches / customers may need to have paperwork such as trainee tracking forms, consent forms / rider information forms. There may also be registers for group training. Such paperwork will need to be carefully and safely stored in a bag when working but consent forms, once checked off, may be returned to the client as soon as they have been checked and registered for. After practical training sessions, all relevant paperwork and folders containing confidential information will be kept locked in secure cabinets (except when in use at a home office) and accessible only by those who need to, and are allowed to, access it for training purposes. Confidential paperwork should be shredded as soon as it is no longer required for Eager Cycle Coaching’s services. 


Electronic information:
Emails containing confidential information should not be sent unless the person working for Eager Cycle Coaching is confident that the relevant person will receive them internally or externally and will be flagged as confidential. Any information concerning personal information can only be forwarded on with permission of those concerned only. Eager Cycle Coaching will only use official email addresses for work-related email communications. 


Multiple client emails:
Where a single email is to be sent out to many customers the following procedures must be followed:

  • Customer email addresses must be collated from spreadsheets or information received / provided by Eager Cycle Coaching admin.

  • All Eager Cycle Coaching-related emails should be double-checked before sending. They should be grammatically correct and should not contain any sensitive data or information. 

  • All group emails must be sent with the BCC email function only, unless being sent to a team or group who know each other.


Electronically held data:
All information held electronically containing sensitive information or personal data will be held under password protected files and on computers that have password or fingerprint recognition access. Computers with Eager Cycle Coaching-related confidential client information on view should not be left unattended or be viewed by anyone not working for Eager Cycle Coaching. Eager Cycle Coaching and its admin staff will be responsible for the storage of information relevant to customer bookings / training at their home office addresses, which are locked properties. Eager Cycle Coaching will ensure that all data is backed up internally when necessary. Confidential information / data no longer in use or outdated / invalid will be held securely for a maximum of 12 months after its last use at which point it will be deleted / disposed of unless by prior arrangement by anyone working for Eager Cycle Coaching, clients, partners, or relevant bodies.


Website cookies:

In simple terms, cookies are small text files that websites place on the computers / mobile devices of people visiting those websites. These files are subsequently read by the website each time the user returns to the site and allow the website to remember the user's device and how they interacted with it. This can be helpful for a number of reasons such as for remembering username and password information so that the user doesn’t have to re-enter login information every time they visit the site. Other functions of cookies are to provide tailored advertising to users based on their search history and personal interests, and site performance cookies that are designed to improve website use by remembering things such as volume settings a user has selected while previously using the website. Since Eager Cycle Coaching's website does not normally contain more specialised content (such as videos), the cookies may primarily benefit users through the website blog experience or the website search bar.


Customer / third party data:
Information received via any third party, which may include sensitive data such as customers’ date of birth or identifying information, must under no circumstances be emailed or sent to any other organisation or party without prior consent of the named individuals (or their carers / guardians) to whom the data concerns. Information that needs to be passed to relating bodies for verification should only be done through secure methods. 


In the event of safeguarding concerns where a safeguarding alert or referral is needed, it may be required for Eager Cycle Coaching coaches / instructors to share private information regarding clients or members of the public. In such cases, coaches / instructors will be obliged to share such information carefully, sensitively, and they must adhere to the Eager Cycle Coaching Safeguarding Policy, which can be made available on request.


Should there be any concerns regarding the way in which Eager Cycle Coaching collates, manages, or uses clients’ personal information or data, then concerns should be raised with Eager Cycle Coaching as soon as possible.


Eager Cycle Coaching will effectively monitor its practices around confidentiality and regularly review this policy.

January 2024
 

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