Privacy Policy

 

Small Shifts is run by Amy Leech as a sole trader.

Your privacy is important to me, and in this privacy notice I share what you can expect me to do with your personal information, it includes:

  1. My contact details
  2. What information I collect, use, and why
  3. Lawful bases and data protection rights
  4. Where I get personal information from
  5. How long I keep information
  6. Who I share information with
  7. How to complain

 

My contact details

Please contact me if you have any queries about the data I hold about you or this privacy notice.

Please use these contact details: smallshifts.co@gmail.com

 

What information I collect, use, and why

I collect or use the following information to provide and improve services for the people I work with:

 

Email subscribers and website enquiries:

  • Your name and contact details 

 

Coaching clients:

  • Your name and contact details 
  • Third party information – emergency contact details
  • Records of meetings and decisions (written and video recordings)
  • Information relating to coaching experience feedback

 

Lawful bases and data protection rights

Under UK data protection law, I must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. Which lawful basis I rely on may affect your data protection rights. You can find out more about lawful bases on the Information Commissioner Office’s (ICO) website here.

If you make a request, I must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact me using the contact details at the top of this privacy notice.

Lawful bases for the collection and use of your data

My lawful bases for collecting or using personal information to provide and improve products and services for people I work with are:

Consent – I have permission from you after I gave you all the relevant information. All of your data protection rights may apply, except the right to object. You have the right to withdraw your consent at any time.

Legitimate interests – I collect or use your information because it benefits you, my work or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. 

My legitimate interests are:

The collection of your name and contact details, emergency contact details, recordings of meeting, and coaching experience feedback is legitimate and necessary because I use this information to provide you with the information and services you requested. For more information on our use of legitimate interests as a lawful basis you can contact me using the contact details set out above.

 

Where I get personal information from

I get personal information directly from you, and from third parties when I’m delivering a service for them.

 

How long I keep information

  • Names and contact details of email subscribers and website enquirers – indefinitely, unless you remove consent
  • Names and contact details of coaching clients – indefinitely, unless you enact the right to erasure
  • Meeting records (notes and recordings) for coaching clients – for 6 months after our work has finished
  • Coaching experience feedback – indefinitely, unless you enact the right to erasure

 

For more information on how long I store your personal information or the criteria I use to determine this please contact me using the details provided above.

 

Who I share information with

Data processors

EcoSend – this data processor provides a platform for sending e-newsletters.

Google – this data processor provides an email service and file storage service.

Others I share personal information with: External auditors

International Coaching Federation (ICF) – this data processor reviews client records for the accreditation of a coaching service

 

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to me using the contact details at the top of this privacy notice. If you remain unhappy with how I’ve used your data after raising a complaint with me, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

 

This privacy notice was last updated in: March 2026