Who we are and what this policy covers
What information NCC may collect about you and when;
How NCC might use your information;
How NCC protects your information; and
Your rights regarding the information you provide.
It applies to information that NCC collects about you when you use the NCC website found here and when you sign up for NCC services. NCC also has a LinkedIn and Facebook page.
Information NCC collects about you
NCC only collects information about you if we have a reason to do so – for example, to provide our Services, to communicate with you, or to make our Services better. We collect information in two ways: if and when you provide information to us and automatically through the NCC website.
Information you provide to NCC
It will probably come as no surprise that NCC collects information that you provide directly. The amount and type of information depends on the context of our relationship and the services NCC is providing.
If you are an individual client, you will provide certain information directly, which may include your name, company, job function or department, address and contact details, such as your telephone number or email address. As part of any coaching programme we will take notes as part of any meetings and if we have video coaching and/or sessions over the telephone, those sessions will be recorded and kept.
If you reach out to NCC via LinkedIn or Facebook and give us your contact details, we will contact you separately (usually by email) using the details you have provided. We do not usually get into a full dialogue with you over either of those platforms.
Information we collect automatically
We may collect, store and use information about your visits to the NCC website and about your computer, tablet, mobile or other device through which you access it. This includes Technical information, including the Internet protocol (IP) address, your login information to our website, your browser type and settings, time zone setting, browser plug-in types and versions, operating system and platform, and geographical location; and information about your visits and use of the Site, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and website navigation and search terms.
This information is not linked to any individual.
Information NCC does not collect
NCC does not generally collect personal data that consists of race or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, genetic or biometric data, health or mortality, sex life or sexual orientation or criminal record information. If NCC does need that type of information though, NCC will only collect it with your express consent.
How and why we use information
Purpose for collecting and using information
If you are a client, we will only collect information in order to provide you with the services we have agreed to provide (the Services) and in accordance with our Terms of Business and also to meet certain legal obligations we have. NCC does not collect more information than is needed in order to provide you with the Services. If you do not provide NCC with the information asked for, we may not be able to provide you with the Services.
If you are a visitor to the NCC website (including completing a form), make a new business enquiry or contact us with a general enquiry, we will process your data for the purpose of responding to those enquiries.
We may also use your information to further develop and improve our Services – for example by adding new features that we think you will enjoy and to monitor and analyse trends and better understand how users interact with us and the services provided by NCC (which helps us to improve our Services for you).
NCC is involved in some exciting things and from time to time we will contact you to let you know about what it is we are getting up to, if we think that you would like to know about it. You can always tell us if you do not want to be contacted in this way.
The personal data you provide to us will only be used for the purpose specified. NCC does not and will not sell, rent or trade your personal data.
NCC sends out a regular email to those awesome individuals who have signed up to receive the NCC newsletter. (The newsletters are sent out using ConvertKit and subscribers can always easily unsubscribe if they want to.)
Legal bases for collecting and using your information
The legal basis for the use of your information depends on the nature of our relationship. In particular:
If the use is necessary in order to fulfil our commitments to you in providing you with the Services (or any other agreements with you);
If we must collect and/or use the information in order to comply with a legal obligation
It we need to protect your vital interests or those of another person;
If we have a legitimate interest in using your information (e.g. to provide and update our services, to improve our services so that we can offer you an even better experience, to safeguard our services, to communicate with you and to measure (and, where necessary improve) the effectiveness of our advertising and/or services;
If you have given us your consent.
NCC may share information with carefully chosen third party organisations that process data on our behalf but NCC will only do so where:
We have permission to do so;
To allow us to provide Services;
We are permitted by applicable law;
We are required to do so by law, court order, legal obligation (i.e. tax offices) or regulatory authorities;
We are legally required for the purposes of prevention of fraud or other crime; or
Where we believe that such action is necessary to protect and defend the rights, property or personal safety of NCC.
For information on these third-party vendors and processors please see the “Third Party Processors” section below.
We will not sell or distribute your information for marketing or any other purpose.
Third Party Links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third-party sites have separate and independent privacy policies. NCC accepts no liability or responsibility for the contents or activities of any third-party websites.
Third Party Processors
Third Party Processors are other organisations/services carefully chosen by NCC to help NCC function and operate as a business. In the case of organisations outside of Jersey and the European Economic Area (EEA) (a) we have prior written instructions for the transfer or (b) we have entered into specific contractual terms with them to ensure that they treat your personal data in way equivalent to that in which they would be required if they were established in Jersey. We will make sure that those organisations are able to keep your information safe.
Information that you provide to us by registering to use the NCC website and consenting (Opt-in) to receiving marking communications such as our newsletter may be shared and stored with our email marketing partner ConvertKit. Your information will only be used to send you marketing communications you have requested. We will not share or distribute your information without your knowledge or consent. You can find information about ConvertKit’s policies here.
Paypal and Stripe
We do not retain a copy of your debit or credit card details.
Location, security and data retention
NCC uses Microsoft Office 365 to store all electronic files and other information in relation to providing the Services. Their servers are not based in Jersey. Information on Office 365 may be found here.
NCC takes appropriate measures to ensure that any personal data are kept secure and are kept for the duration of your use of our service and NCC only uses third party processors who can provide the requisite levels of assurance in respect of data security. (Unfortunately, the transmission of information via the internet is not completely secure.)
In the absence of other instructions from our clients, or unless otherwise required for legal or regulatory purposes, it is NCC’s policy to retain correspondence and other papers in NCC’s Microsoft 365 account for at least five years and then to periodically destroy documents older than that (other than documents which we consider may be of continuing significance). Recordings on Voxer and Zoom will be kept for the same period. NCC thinks that this is appropriate because you may receive services over a prolonged period, or you might move jobs and want to receive some further coaching, building on the work we’ve done together previously. Being able to access the work we did for you will make it easier for NCC to continue to deliver outstanding coaching to you. If you do not want NCC to keep your information for that long, let us know and we can discuss this with you.
Data protection legislation provides data subjects with a number of rights. These include:
The right know what type of personal data we hold about you, given details about how we use it and to be provided with a copy of the personal data held;
The right to have an errors or omissions corrected;
In certain circumstances, the right to request erasure of all your personal data that we hold;
The right to request we restrict the processing of your personal data;
The right to object to the further processing of your personal data, including the right to object to direct marketing;
The right to withdraw consent if you had previously given use consent to process your data;
The right to request that Personal Data be moved to a third party;
The right to lodge a complaint.
When you make a request to NCC about exercising any of the rights listed above we will consider any lawful exemptions that may apply and that may prevent us from responding to your request in the manner you may wish. It is possible that there is something that may prevent us from responding to your request in the way you would like. If that is the case, we will explain this to you in writing when we respond to your request.
Complaints or queries
We aim to meet the highest standards when processing personal data.
If at any stage you became dissatisfied with the manner in which we collect, hold or process your personal data or if you have any questions, please contact us.
Telephone: +44 (7797) 781 203
You also have the right to contact Jersey’s Data Protection Authority c/o the Information Commissioner.