Privacy notice
Last updated
I am Siôn Stansfield, trading as 7th Street, a sole trader registered in the UK. This notice tells you what I do with your personal information, in plain English. If anything here is unclear, email me at sion@sionstansfield.com and I will answer.
Who is responsible for your information
I am. I decide what happens to it and I am answerable for it.
My business address is 2 Fountain Place, Worcester, WR1 3HW, United Kingdom.
My business is in the UK and my clients are in the UK, so the UK GDPR applies to everything I do with your information, and the UK regulator, the Information Commissioner’s Office, oversees me.
I live and work in France, so the EU General Data Protection Regulation applies as well, and the French regulator, the CNIL, can also act.
I do not have a data protection officer. The business is one person. Contact me directly.
What I collect, and why
When you book a call The form asks for your name, your email and, if you want to give it, one line on what is happening in your role. I use them to reply to you, to arrange the call, and to come to it prepared. I do not add you to a mailing list. I do not send you marketing. I do not use your details for anything else. Please do not put anything about your health in that line. You do not need to, and I would rather hear it from you in person, if you choose to tell me at all.
When we have the discovery call The call is coaching, so I treat it exactly as I treat a paid session. I keep a short note of what we talked about. If you do not go on to work with me, I delete that note, your booking and our emails 12 months after the call. If you do, it becomes part of your client record below.
When you become a client I keep your contact details, the terms you accepted, your invoices and payments, my notes from our sessions, the one-page summary I send you after each session, the emails we exchange between sessions, and the things we make for the work: your two Week Maps, one at the first call and one at session six; your Stop List; your Mine, theirs, nobody’s list of decisions; and your 90-Day System. I use them to deliver the programme, including the check-in after session six, and to keep a proper record of the work. Sometimes a client chooses to tell me about their health, including stress or sleep. If you do, I will only write it down with your clear agreement, and I will keep it to what is needed for the coaching. I do not record sessions. If we ever agree to record one, I will ask at the start of that session, and I delete the recording 30 days after the programme ends.
If a client names you in their work Some of the work names other people. The decisions list can say whom a decision goes to, and a Stop List or a 90-Day System can mention a colleague. If you work with one of my clients, I may hold your name or your role, and the piece of work it sits beside, in that client’s record. I hold nothing else about you. I use it only for that client’s coaching, I never contact you, and I never pass it to anyone. I write down a first name or a role, whichever my client gives me, and no more. I do not tell each person named, because that would break my client’s confidentiality. This notice is how I tell you.
When your employer pays for your coaching Some of this work is paid for by the employer of the person doing it. If that is you, this is what happens to your information.
I keep the contact details of the person at your employer who arranged and pays for it, their purchase order, and the invoicing record.
Your employer is told two things by me, and only two: that you attended, with the dates, and the focus areas of the work. A focus area is a short phrase that names the kind of work, not the substance of it.
You and I agree the exact words before your employer sees them, in writing, at the start. If we cannot agree a phrase, your employer is told that you attended and the dates, and nothing else.
Your employer is never told the content of a session, anything you fill in for the work, your Stop List, your decisions list, your 90-Day System, the summaries I send you, my notes in any form, or my opinion of you. If they ask me for any of it, the answer is no, and I will tell you that they asked. The exceptions are the ones you choose, under the Three-Way Agreement below.
If you use the guarantee in my terms, your employer is told that the programme has ended and the fee has been refunded, and nothing about why.
I ask you to confirm in writing, before your first session, that you agree to those two things and to the exact words. I keep that confirmation for as long as I keep your client record. You can withdraw it at any time, and from that point your employer is told that you attended and the dates, and nothing else.
Once your employer has been told those things, your employer is responsible for what it does with them, not me. Its own privacy notice applies to that, not mine.
The same rule is written into my terms, under “If your employer pays”, so it is a promise you can hold me to and not only a description of what I do.
The Three-Way Agreement: the meeting before session one This applies only if your employer pays, and only if you agree to it. Before the meeting we agree in writing who joins and the objectives you are willing to put forward. At the meeting your manager or sponsor hears those objectives and our discussion of them, with you there, and nothing else. They hear nothing from the discovery call, and nothing from the coaching that follows. Afterwards I send the agreed objectives to you and to them. I keep the objectives, your written agreement, and your manager’s or sponsor’s name and work email as part of your client record. I never report on the objectives to anyone. If you would rather not have the meeting, it does not happen, and your employer is told only that you chose not to.
The last fifteen minutes of session six This only happens if you ask. Your manager or sponsor joins if your employer pays; if you pay for yourself, your manager can join on the same terms. Before the session we agree in writing who joins and what is shown and said. They see your two Week Maps, and hear only what you have agreed. Before then we go through the maps together, and anything you do not want them to see, including anything about your health, comes off them. They are given no copy unless you give one yourself. You can change your mind at any time, up to and during the session. I keep their name and work email to send the call link, and your written agreement, as part of your client record. Anything your manager or sponsor keeps or writes down from either meeting is then your employer’s responsibility, under its own privacy notice, not mine.
When you visit this site The company that hosts this site, Netlify, records your IP address, your browser type and the pages you view, for security and to keep the site running.
Netlify also counts visits for me from those same server records: how many pages are viewed, which pages, roughly which countries visits come from, and how many different IP addresses visit in a day. There is no cookie and no tracking script, and nothing is stored on your device. I see totals. I never see who you are, and I do not try to find out.
The legal reasons I rely on
The law says I need a reason for each use of your information. Mine are these.
- Replying to your booking and having the discovery call: because you asked me to, as a step before any contract between us.
- Delivering the programme, including the Week Maps, the Stop List, the decisions list, the 90-Day System, the summaries, the emails between sessions and the check-in: because it is the contract between us.
- Holding the names or roles of colleagues a client names in the work: my legitimate interest in delivering the coaching my client has asked for. That is balanced against your privacy by holding only a first name or role, using it for nothing else, and never contacting you or passing it on.
- Telling an employer who pays that you attended and the focus areas: my legitimate interest, and theirs, in being able to account for money they have spent. That is balanced against your privacy by the fact that you agree the exact words first, that the list is only two items, and that you can stop it at any time.
- The meeting before session one, and keeping the agreed objectives: my legitimate interest, and your employer’s, in agreeing what a programme it pays for is judged on. That is balanced against your privacy by your choosing the objectives in writing first, by your being there throughout, and by your being free to say no.
- Showing your two Week Maps to your manager or sponsor in session six: your consent, given in writing before the session, which you can withdraw at any time up to and during it.
- Keeping your manager’s or sponsor’s name and work email to arrange either meeting: my legitimate interest in arranging the meeting you agreed to.
- Keeping records after a programme ends: my legitimate interest in keeping a proper record of the work and in being able to deal with any dispute.
- Keeping invoices and accounts: the law requires it.
- Running and securing the website, including the spam check on the form: my legitimate interest in a site that works and an inbox that is not full of junk.
- Counting visits to the site: my legitimate interest in knowing whether the site is being used, using totals only.
- Anything you tell me about your health: your explicit consent, which you can withdraw at any time.
I do not make any decision about you by automated means. The spam check on the form only decides whether a message reaches my main list of messages or a spam list, and I check both.
Who else sees your information
I use a small number of companies to run the business. Each one handles your information only to do that job for me, under a written agreement.
- Netlify hosts this site, receives the booking form and counts visits. Netlify, Inc. is in the United States. It keeps a copy of each form message until I delete it, and sends it on to me by email.
- Akismet, a service run by Automattic Inc. in the United States, which Netlify uses to check each form message for spam.
- My email provider, which holds my inbox, including the emails the form sends me, the summaries I send you, and our correspondence.
- The video call service we use for the discovery call, for sessions, for the meetings with your manager or sponsor, and for the check-in. Calls pass through it. I do not record them.
- My bank, which receives your payment, and my accountant, for the financial records only.
If your employer pays for your coaching, the person at your employer who arranged it also sees the two things set out above. That employer is a separate organisation making its own decisions about that information, not a company acting on my instructions.
If you agree to the meeting before session one, your manager or sponsor hears the objectives you chose to put forward, and receives them in writing afterwards.
If you ask for your manager or sponsor to join session six, they see your two Week Maps and hear what you have agreed, during that call, and nothing else.
Your Stop List is written for you to send. Whom you send it to is your choice, not mine.
I do not sell your information. I do not share it with anyone else unless the law requires me to.
Sending information between countries
I work from France, which is in the European Union.
Information you send me from the United Kingdom can come to me in France because the UK government has decided that the EU protects personal information to a standard it accepts.
Information I send to the United Kingdom, for example to an employer who pays, can go there because the European Commission has decided the same about the UK.
Where any of the companies above is in the United States, your information is protected in one of two ways: by the EU-US Data Privacy Framework and its UK Extension, where the company is certified under it, or by the standard contract clauses approved for transfers, which form part of the agreements that cover them.
How long I keep it
- Booking form messages in Netlify: deleted within 30 days of the message arriving. The email copy stays in my inbox under the next two lines.
- If we do not go on to work together: your booking, our emails and my note of the discovery call, 12 months after the call, then deleted.
- Client records, including session notes, the session summaries, both Week Maps, the Stop List, the decisions list, the 90-Day System, the objectives agreed before session one, the written agreement about what an employer is told, and any written agreement about a manager or sponsor joining a meeting: six years after the programme ends, which covers the period during which a legal claim could be brought. Then deleted. The programme ends at the check-in, or three months after session six if the check-in is not held.
- Names or roles of colleagues in a client’s Stop List or decisions list: kept with those documents, for the same six years, then deleted with them.
- Invoices and accounts: six years after the end of the tax year they belong to, which covers what HM Revenue and Customs requires.
- Recordings, if we ever agree to make one: 30 days after the programme ends.
- Website server records and the visit counts made from them: whatever Netlify keeps, which I do not control.
- Contact details for the person at an employer who arranged coaching: 24 months after our last contact, unless an invoice means I must keep them longer.
Your rights
You can ask me:
- for a copy of the information I hold about you
- to correct it if it is wrong
- to delete it
- to stop using it, or to limit how I use it
- to send it to you or to someone else in a usable format
- to object to my using it where I rely on legitimate interests, including what I tell an employer who pays
- to withdraw any consent you have given
Email sion@sionstansfield.com. I will reply within one month. There is no charge. I may need to check who you are first.
If you are unhappy
Tell me first. Email sion@sionstansfield.com with the word “complaint” in the subject line. I will acknowledge your complaint within 30 days and tell you what I have done about it.
You can also complain to a regulator at any time.
If you are in the United Kingdom: the Information Commissioner’s Office, ico.org.uk/make-a-complaint, 0303 123 1113.
If you are in France or elsewhere in the EU: the CNIL, cnil.fr/fr/plaintes, or the regulator in the country where you live.
Cookies
This site does not set cookies. It does not store anything on your device. It does not load scripts from advertising, analytics or social media companies. The visit counts above are made by Netlify from its own server records, not by anything running in your browser. The typeface is served from this site, not from a font company. The booking form sends your message to Netlify when you press the button. Nothing is stored on your device.
Children
My work is for adults in work. I do not knowingly collect information from anyone under 18.
Changes
If I change this notice I will change the date at the top. If the change matters to you and I have your email address, I will tell you.
Contact
Siôn Stansfield, trading as 7th Street 2 Fountain Place, Worcester, WR1 3HW, United Kingdom sion@sionstansfield.com