Policies

In no way can any rights be derived from, or claims made, with regard to the content of this website.  Although the greatest possible care has been taken with the compilation of the content of this website, it is possible that, after a while, certain information may be out-of-date or no longer be correct.  Where this content is used without the International Regulator of Coaching & Mentoring CIC (IRCM) knowledge or confirmation, the IRCM cannot be held responsible for any damages arising from the use of information from this site.  IRCM hereby rejects all responsibility for damages as a result of the use of this information or information to which links refer on this site or any IRCM related site.

The information on this site may be changed without prior warning.

IRCM does not give guarantees with regard to the nature and the content of this site information and is not responsible for the content of this information or for the usage thereof.  All responsibility for possible damages due to access to and use of the information held on this site is explicitly rejected by IRCM. Moreover, no guarantee is given for the faultless and continuous functioning of the site. References or connections to other sites or sources which are not the property of IRCM are only included as information for the user of this site, and the IRCM is not responsible for the availability of these sites, information held, or sources.  The IRCM does not accept any responsibility with regard to the content, advertisements, products, or other issues on such sites or sources or availability.  IRCM is not responsible for any kind of damage or loss caused by or in connection with the use of, or by relying on the content, products or services offered on such sites or sources.

We use cookies and this section deals with how the information obtained through this Internet site is gathered and used.

Web server log data

When our Internet site is visited, a log is registered on our web server. This log provides us with non-personal data about the date and time of logging in, as well as the IP address and the browser type from which our Internet site is visited. The information from these server logs is used by our development team for Internet optimisation of our own site(s) and those of our present and future clients.

Approval of privacy statement

The use of our Internet site automatically means the approval of our privacy statement and use of cookies. If you do not agree with our privacy statement, we kindly request you to leave our site.

IRCM reserves the right to change this statement without prior announcement.

The copyright statement is found at the footer of each page of the IRCM website(s).

The information and materials contained on this site are either the copyright of individual coaches, mentors, training organisations, professional bodies, commercial organisations, contributors, consumers, complainants, respondents, or of International Regulator of Coaching and Mentoring CIC, and may also be subject to other intellectual property rights.

Whilst the pages may be copied for the purpose for which the site is intended, such copies may only be used by you within your organisation, and not for any commercial use or benefit without the express consent of International Regulator of Coaching and Mentoring CIC, for which a fee may be charged.

Whilst the pages may be linked to for the purpose for which the site is intended, such links may only be linked on your website, and not for any other commercial use or benefit without the express consent of International Regulator of Coaching and Mentoring CIC, for which a fee may be charged.

All copyrights and trademark notices, marks, disclaimers and other such elements must be preserved and upheld at all times.

These conditions are governed by and will be interpreted in accordance with English Law and any disputes relating to these conditions will be subject to the exclusive jurisdiction of the English courts.

Introduction

As with all businesses, the International Regulator of Coaching and Mentoring CIC (IRCM) needs to gather and use certain information about individuals and organisations.

The information gathered and used includes Coaches, Mentors, Training Organisations, Professional Bodies, Commercial Organisations, Consumers, and the IRCM team, as well as other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards – and to comply with the law.

Why this policy exists

This data protection policy ensures the IRCM:

  • Complies with UK Data Protection Legislation and follows good practice
  • Protects the rights of staff, Coaches, Mentors, Training Organisations, Professional Bodies, Commercial Organisations, Consumers, partners, and others
  • Is open about how it stores and processes organisations and individual’s data
  • Protects itself from the risks of a data breach

Data Protection Legislation

The Data Protection Act 2018 describes how organisations must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper, or using other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles.  These say that personal data must:

  1. Be processed fairly and lawfully
  2. Be obtained only for specific, lawful purposes
  3. Be adequate, relevant and not excessive
  4. Be accurate and kept up to date
  5. Not be held any longer than necessary
  6. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways
  8. Not be transferred outside of the European Economic Area (EEA) unless that country or territory also ensures an adequate level of protection

People, risks and responsibilities

Policy scope

This policy applies to:

  • The IRCM team in all international locations
  • The locations of permanently based local and remote workers
  • All staff and volunteers of the IRCM
  • All contractors, suppliers and other people working on behalf of the IRCM

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 2018.  This can include:

  • Names of individuals, including prefixes and suffixes
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • Listed, Registered, or Accredited information
  • IRCM Ombudsman Service Register of Complaints, Outcomes, and Sanctions
  • plus any other information relating to individuals, organisations and/or their business.

Data protection risks

This policy helps to protect the IRCM from some very real data security risks, including:

  • Breaches of confidentiality. For instance, information being given out inappropriately
  • Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
  • Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with the IRCM has responsibility for ensuring data is collected, stored and handled appropriately, and that it is processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

The Company Directors are ultimately responsible for ensuring that the IRCM meets its legal obligations.

The Data Protection Officer is responsible for:

  • Keeping the Company Directors and the IRCM team updated about data protection responsibilities, risks and issues
  • Reviewing all data protection procedures and related policies, in line with an agreed schedule
  • Arranging data protection training and advice for the people covered by this policy
  • Handling data protection questions from staff and anyone else covered by this policy
  • Dealing with requests from individuals and organisations to see additional data the IRCM holds about them (also called ‘subject access requests’)
  • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data

The IT Manager is responsible for:

  • Ensuring all systems, services and equipment used for storing data meet acceptable security standards
  • Performing regular checks and scans to ensure security hardware and software is functioning properly
  • Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

The Marketing, Business Development, Compliance, Future Development, and Register Directors are responsible for:

  • Approving any data protection statements attached to communications such as email and letters
  • Addressing any data protection queries from journalists or media outlets like newspapers
  • Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles

General staff guidelines

  • The only people able to access data covered by this policy should be those who need it for their work.
  • Data should not be shared informally. When access to confidential information is required this can be requested from the relevant Director.
  • The IRCM will provide training to the whole IRCM team to help them understand their responsibilities when handling data.
  • The IRCM team should keep all data secure by taking sensible precautions and following the guidelines below.
    • In particular, strong passwords must be used and they should never be shared
    • Personal data should not be disclosed to unauthorised people either within the company or externally
    • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required it should be deleted and disposed of.
    • The IRCM team should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection

Data storage

These rules describe how and where data should be safely stored.  Questions about storing data safely can be directed to the IT Manager or Data Protection Officer.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

  • When not required, the paper or files should be kept in a locked drawer or filing cabinet
  • The IRCM team should make sure paper and printouts are not left where unauthorised people could see the pages i.e. on a shared printer
  • Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared between the IRCM team
  • If data is stored on removable media these should be kept locked away securely when not being used
  • Data should only be stored on designated drives and servers, and should only be uploaded to approved cloud computing services
  • Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones
  • All servers and computers containing data should be protected by approved software and a firewall

Data use

Personal data is of no value to the IRCM unless the business can make use of it.  However, it is of value when personal data is accessed and used for reasons not designated i.e. loss, corruption or theft:

  • When working with personal data, each member of the IRCM team should ensure the screens of their computers are always locked when left unattended
  • Personal data should not be shared informally.  In particular, it should never be sent by email as this form of communication is not secure
  • Data must be encrypted before being transferred electronically.  The IT manager can explain how to send data to authorised external contacts.
  • Personal data should never be transferred outside of the European Economic Area unless the personal data relates to an individual outside the European Economic Area.
  • The IRCM team should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data accuracy

The law requires the IRCM to take reasonable steps to ensure data is kept accurate and up to date.

It is the responsibility of all members of the IRCM team who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible

  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming a individual’s details when they call.
  • The IRCM will make it easy for data subjects to update the information the IRCM holds about them.
  • Data should be updated as inaccuracies are discovered. For instance, if an individual can no longer be reached on their stored telephone number or email address, it should be removed from the database
  • It is the Business Development Manager’s responsibility to ensure all business development related databases are checked against industry suppression files every six months

Subject access requests

All individuals who are the subject of personal data held by the IRCM are entitled to:

  • Ask what information the company holds about them and why
  • Ask how to gain access to it
  • Be informed how to keep it up to date
  • Be informed how the company is meeting its data protection obligations

If an individual contacts the IRCM requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at directors@IRCM-CIC.org.  The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be not be charged for their subject access request.  The Data Protection Officer will aim to provide the relevant data within 14 days.

The Data Protection Officer will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, the IRCM, will disclose requested data.  However, the Data Protection Officer will ensure the request is legitimate, seeking confirmation from the Board and from the company’s legal advisers, where necessary.

Providing information

The IRCM aims to ensure that individuals are aware that their data is being processed and that they understand:

  • how the data is being used
  • how to exercise their rights

To these ends, the company has a privacy statement setting out how data relating to individuals is used by the company.

The International Regulator of Coaching and Mentoring CIC (IRCM) holds multiple public accessible registers of Coaches, Mentors, Training Organisations, Professional Bodies, and Commercial Organisations.

The IRCM holds multiple confirmation registers which include Future Development; Compliance and Accreditation Processing; and the IRCM’s Ombudsman Service Register of Complaints; Outcomes; and Sanctions.

Each publicly accessible register is made available to the consumers as a verification of their standing in the coaching and mentoring industry, and is based on the information provided by the individuals for themselves or for their organisations and includes:

Professional Bodies: the following information is held:

Listed – name of the Professional Body. type of legal entity structure (if known), Register Status, Trading status

Registered – are those organisations who have agreed to abide by the Unified Code of Industry Ethics, Unified Industry Core Competencies, Disciplinary Procedures, and recognises the Ombudsman Service for consumers (their members).  For these organisations we record the name of the Professional Body, trading status, insurance status, trading start date, legal entity structure, legal entity reference (if applicable), addresses (all address applicable), the website details, an email contact, telephone number, description, whether they cover coaches, mentors, training organisations, contact button, and confirmation of the statements above.

Accredited – as registered plus full details of each membership level detailing the accreditation verification information.

Although the IRCM focused on registering and accrediting Professional Bodies, those Training Organisations who select to hold their information on the IRCM Register, the following information is held:

Listed – name of the Training Organisations, Register Status, Trading status

Registered – are those organisations who have agreed to abide by the Unified Code of Industry Ethics, Unified Industry Core Competencies, Disciplinary Procedures, and recognises the Ombudsman Service for consumers (their students).  For these organisations we record the name of the Training Organisations, trading status, insurance status, trading start date, legal entity structure, legal entity reference (if applicable), addresses (all address applicable), the website details, an email contact, telephone number, description, whether they cover coach training, mentor training, contact button, and confirmation of the statements above.

Although the IRCM focused on registering and accrediting Professional Bodies, those Coaches and Mentors who select to hold their information on the IRCM Register, the following information is held:

Listed – name of the Training Organisations

Registered – are those individuals who have agreed to abide by the Unified Code of Industry Ethics, Unified Industry Core Competencies, Disciplinary Procedures, and recognises the Ombudsman Service for consumers (their clients).  For these organisations we record the name of the individual, trading status, insurance status, trading start date, legal entity structure, legal entity reference (if applicable), addresses (all address applicable), the website details, an email contact, telephone number, languages, specialities, description, whether they offer coaching and/or mentoring, contact button, confirmation of the statements above, and details of their accreditation/credential and training.

Corporate Organisations are organisations who may employ (directly or indirectly) coaches and/or mentors, or who support the coaching and mentoring industry.  These organisations who select to hold their information on the IRCM Register, the following information is held:

Listed – name of the Organisation, Register Status, Trading status and business type.

Contact forms

There are various forms built into the IRCM website.  Each form allows for specific information to be registered.  This information is held within a database and is only used for the purposes determined by the reason for the form.

Although the IRCM can confirm the register status, the detail held on these publicly available registers is submitted by the individual for themselves or for their organisation and it is the responsibility of each individual to verify the information they select to use.  The REGISTERED and ACCREDITED information was correct at the time of application or renewal and it is the responsibility of the relevant individual for themselves or their organisation to provide regular updates as necessary.  For this reason, the IRCM cannot guarantee that the information displayed is current and up-to-date.  The extent to which you may relay on the information displayed is in the hands of the relevant individual

Each confidential register is held for the purposes determined below and is only available to the relevant department and the IRCM team allocated to the work within that department.

Ombudsman Service Register of Complaints, Outcomes, and Sanctions.

Department – Compliance and Accreditation (responsible for the Ombudsman Service)

This register is used to record all complaints, outcome, and relevant sanctions.  This register is utilised to ensure that each complaint registered progresses through the relevant processes to an outcome.  As explained on the Ombudsman Services page, the information held here may be used should more than one complaint be registered by a complainant or against a respondent.  This information allows the Ombudsman Service to identify continuing injustices and to provide the Future Direction Department with an outline of the injustices without provide any confidential details or information such that they may work with the Steering Committee and where applicable relevant parties to make a change to the coaching and mentoring industry.

The information held on this register pertains only to forms registered on the Ombudsman Service webpage and all relevant processing.

The summary information includes the date lodged, the name of the complainant, the name of the respondent, reason for the complaint, the date the outcome was issued, sanctions awarded against the respondent, complainant or others, sanctions lifted against the respondent, complainant or others.

The detail information shows the summary information as above, the form as it was submitted, any additional information submitted by the complainant, information submitted by the respondent, the outcome, and sanctions issued.

It is important to note that although this register is confidential only to the Compliance and Accreditation Department; that is may be audited by the relevant UK Government Authorities.

Future Development

Department – Future Development

The role of the Future Development Department is to continue to review the coaching and mentoring industry and make recommendations or changes where applicable.

The information held on this register is the detail of each survey entry and the discussion notes and decisions made by the Steering Committee.

Compliance and Accreditation Processing

Department – Compliance and Accreditation.

The information held within these databases allows the IRCM to confirm that the relevant individual for themselves or their organisation has provided the right level of information and progressed through the relevant processes to ensure that the information held is accurate.

Registered databases – these database hold the relevant information for the individual or organisation and confirmation that each individual for themselves or on behalf of their organisation has agreed to abide by the Unified Code of Industry Ethics, Unified Industry Core Competencies, Disciplinary Procedures, and recognises the Ombudsman Service for consumers.

Accredited databases – hold the information detailed under Registered Database and all relevant information for granting, or not, an accreditation status.  This is only relevant to Professional Bodies.

In line with business development, legislative requirements, or other such matters; the information held on the registers may change without notice.

The refunds policy only applies to those coaches, mentors, training organisations, professional bodies, commercial organisations or others who have REGISTERED or ACCREDITED listings.

As an individual or organisation with a Registered or Accredited listing on the International Regulator of Coaching and Mentoring CIC’s (IRCM) Register, you have the right to cancel your registered or accreditation application or upgrade within 7 days of your initial upgrade/application date.

Cancellation of your upgraded listing or application can only be done by email to the relevant Department and the refund will be done through your PayPal account and where applicable, you will be refunded less the PayPal charges to your PayPal account.

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© 2018 International Regulator of Coaching and Mentoring CIC. All Rights Reserved
Version  6, May, 2018