Privacy Policy

Privacy Policy

TXG values the privacy of those who provide personal information to us.  This privacy policy (the “Policy”) describes how and why we collect, store and use personal information, and provides information about your individual rights.

This Policy applies to both personal information supplied to us either by an individual or by others.  We may use personal information supplied to us for any of the purposes as set out in this Policy, or as otherwise disclosed at the point of collection.

This Policy is an important document. We recommend that you read it carefully and print and keep a copy for your future reference.

In this Policy, we use the terms:

• “TXG”, “we”, “us”, and “our” (and other similar terms) to refer to The X Group (TXG) Limited (registered company number: 05236150)
• “Personal Information” is any information relating to an identified or identifiable natural person;
• “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors; and
•  “you” and “your” (and other similar terms) refer to our clients, individuals associated with our clients, coachees, contacts, suppliers, associate coaches, consultants and sub-contractors, business contacts, job applicants, staff and visitors to the TXG website, www.txgltd.com.

Your rights in relation to Personal Information and how to exercise them

Under certain circumstances you have the following rights:

• the right to ask us to provide you, or a third party, with copies of the Personal Information we hold about you at any time and to be informed of the contents and origin, verify its accuracy, or else request that such information be supplemented, updated or rectified according to the provisions of local law;

• the right to request erasure, anonymisation or blocking of your Personal Information that is processed in breach of the law;

• the right to object on legitimate grounds to the processing of your Personal Information. In certain circumstances we may not be able to stop using your Personal Information, if that is the case, we’ll let you know why; and

• withdrawal of consent – while we do not generally process Personal Information on the basis of consent, if Personal Information is ever processed on the basis of consent an individual may withdraw this consent at any time (this may apply to processing of special categories of Personal Information including the following: racial/ethnic origin, political opinions, religious or philosophical beliefs and trade union membership).

To exercise such rights and if you have any questions about how we collect, store and use Personal Information, then please contact us using the details as set out at the end of this Policy.

What basis do we have for processing your Personal Information?

We will only process personal Information where we have a lawful reason for doing so.  The lawful basis for processing Personal Information by us will be one of the following:

• the processing is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract (for example, you have approached us to be an associate coach or we have approached you to consider becoming an associate coach);
• the processing is necessary in order for us to comply with our legal obligations (such as compliance with legislation);
• the processing is necessary for the pursuit of our legitimate business interests including that of the delivery of our services (for example, we have been introduced to you to potentially provide coaching services to you or your organization);

The Information we collect:

Depending on the circumstances, the information we may hold for you may include:

Business contacts:

Your full name

Your contact details (email, preferred contact numbers, home address)

Your company name and job title

Your area of business

Other business contact information

Associate coaches:

Your full name

Your contact details (email, preferred contact numbers, home address)

Your company name and job title

Your CV/Coaching Profile

Your areas of specialization and qualifications

The geographical areas you work in and languages you speak

Details of work undertaken with TXG, such as session rates and timings

References taken on you

Coachees/Clients

Your full name

Your company name and job title

Your job role and areas of responsibility

Information shared by you as part of the briefing or coaching arrangement

Coaching briefs on either the coaching to be undertaken or the work you have undertaken with TXG

Details of work undertaken with TXG, such as session rates and timings

What we do with that information?

We use your contact details to:

• Contact you to discuss potential work opportunities/potential coaches
• Keeping you informed of developments at TXG and the services we offer that we believe may be relevant to you
• Sending requests for your thoughts on key subjects such as our recommended book list and then sending through the collated responses
• Scheduling meetings
• Billing purposes
• To share news about any events we are organising or participating in
• Performing analytics – such as trends and coach success rates.

TXG’s relationship with you:

TXG acts as an intermediary, and so we have set out below specifically how we share data between our clients/coachees and our associate coaches, both of whom are third parties.

Associate coaches – With potential coaching and consulting opportunities, we may wish to share your contact details with a potential client, but we will always request your permission before sharing any personal information.

Clients/coachees – Our coaches are required to keep a record of the number of hours they have coached and the individuals they have worked with each year and your name, company and email address are kept indefinitely but this information is only ever shared with the professional body to ensure the coach is maintaining the standards necessary for professional registration.

In addition, each coach will often keep notes of individual coaching conversations taken during and post a session.   These notes may be held on paper and/or electronically.  Our associates keep your data individually – this is not shared with anyone else at TXG without your express permission.  Our associate coaches and consultants are all bound to adhere to this Privacy Policy as a condition of working with us.

Session notes may be kept for a maximum period of four years from the completion of the coaching assignment and then archived for a maximum of six years before being destroyed.  You can request a copy of your data as stipulated by the legislation.

Who else may have access to your Personal Information?

On occasion, in addition to the specific sharing set out above, we may need to share your Personal Information with third parties.  We will only share Personal Information where we are legally permitted to do so.

Where you supply us with Personal Information as a client or an associate coach, we will assume, unless you instruct us otherwise in writing, that we can disclose your Personal Information in such manner as we believe is reasonably necessary to provide our services (including as described in this Policy), or as is required under applicable law. For example, we may pass your Personal Information to third parties such as:

• professional regulatory bodies
• providers who administer psychometric tests where that is appropriate for a coaching relationship.  We will provide contact details to those providers only for the purpose of initiating the service.  Some of these providers may be outside the EU and we endeavour to ensure they comply with the relevant data protection legislation
• disclosures required by law or regulation: in certain circumstances, please note that we may be required to disclose Personal Information under applicable law or regulation, including to law enforcement agencies or in connection with proposed or actual legal proceedings
• credit-checking agencies for credit control reasons
• events: we may need to pass on your Personal Information (e.g. name, company, occupation) to a third party in connection with management of an event, in which case the details will only be used by the third party for that specific purpose
• business partners, service providers and other affiliated third parties: to enable us to provide our services to you, we may need to share your Personal Information with our business partners (including professional advisers such as accountants or auditors), or external service providers. Our arrangements with external service providers currently cover the provision of support services including IT, events management, document production, business research, accounting, administration, bookkeeping and secretarial services.

How we hold your data: Confidentiality & Security

TXG works with Salesforce to keep and maintain the personal information we hold.   Salesforce are based outside the EU but comply with all the privacy and security provisions required by the GDPR.

TXG treats the information you provide us with as confidential and we do not sell any personal data on to third parties and we only share any personal information for legitimate business reasons.

TXG protects your information through administrative measures from all our staff both electronically and physically, including electronic cyber security systems such as firewalls on all of our electronic equipment.

The conditions where we cannot maintain confidentiality is where we are become aware of illegal activity or where the physical or mental health of the coachee or others is, in our judgement, seriously at risk.

Links to other websites

The TXG website www.txgltd.com may link to other, unaffiliated third-party websites.  Please note that TXG is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third-party websites.  You must always carefully review the privacy and confidentiality policy of any third-party website that you may visit in order to understand how the operators of that website may collect, store and use your Personal Information.

Updates to this Policy

This Policy was last updated in May 2018.  Please check back regularly to keep informed of updates to this Policy.

Removing your data:

You are able to be deleted from our database at any time by contacting Catherine Rick (Catherine.rick@txgltd.com) and we will ensure you are not contacted in the future unless we receive a written request from you.

Data Controller and Privacy Officer:

TXG is a data controller and our CEO is our Privacy Officer.  If you would like to exercise your rights as set out in this Privacy Notice, you may contact Michelle Walder on michelle.walder@txgltd.com or by telephone +44 (0)20 7592 2727.

Complaints

While we hope that you will not need to, if you do wish to complain about our use of Personal Information please send an email detailing your complaint to the Privacy Officer above.

You also have the right to lodge a complaint with the supervisory authority at:

Information Commissioner’s Office:

Wycliffe House, Water Lane

Wilmslow

Cheshire

SK9 5AF

www.ico.org.uk

Tel: 0303 123 1113

Tel: 029 2067 8400 (calls in Welsh)

Email: casework@ico.org.uk