This privacy notice provides you with details of how Wellbeing – Trusted Circle Ltd (“we”, “our”, “us”, or “the Company”) collects and processes your “personal data”, whether you are a client, candidate, supplier, or a third party.
To enable us to carry out our core business and ancillary activities, (“we”) may collect and process information about you from a selection of sources which includes but are not limited to:
1. When you enter your information on a contact form on our website. The data controller
for this data is “the Company”.
2. When you enter your information into a newsletter subscription form. The data controller for this data is “the Company”.
3. When information is received through networking activity by an employee of “the Company” about yourself or your company and where it is understood there is a legitimate interest in receiving services from us. The data controller for this information is “the Company”.
4. When your company or employing company enters into a client agreement with a business with “us” and provides information about you to us to receive any other services and/or resources offered by us. In this case, only information about you that is relevant to the delivery of these services should be shared by your employer with “us”. The data controller for this information is your company or employing company.
Definitions:
“Personal Data”: any information identifying a living, identifiable individual, excluding any anonymous data but including any sensitive Personal Data.
Such data can be factual such as a name, email address, date of birth or national insurance number, or an opinion or reference about a person’s actions or behaviour.
“Processing” or “Process”: any activity involving the use of Personal Data whether that is obtaining, holding, recording or carrying out any operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. It includes the transmission or transferring Personal Data to third parties.
What sort of information about you is being collected and processed by us?
Under the Data Protection Act (2018) and GDPR regulations, we only collect any “necessary” information required to allow us to promote and deliver our services fairly and effectively.
How can you find out what information we hold about you?
Under the Data Protection Act (2018), and European GDPR regulations, EU) 2016/679) (“GDPR”) any person about whom organisations hold data (a ‘data subject’) can request a copy of that information. This is called a Subject Access Request (‘SAR’).
Guidance is available for individuals who wish to make a SAR on the Information Commissioners Office (ICO) website, which is the regulator. Their website is: https://ico.org.uk/
There is also information on this site about requirements for SARs for both the requesting and responding parties, and who SARs should be sent to. If you wish to make a subject access request to us, this should be submitted by email to hello@wellbeingtrustedcircle.comor by post to 51 High Street Mold Flintshire CH7 1BQ
If you are not happy with any aspect of how we collect and use your data, you also have the right to complain, to the ICO, mentioned above. However, if you have a complaint, or you are unhappy with the way we collect and use our data, please contact us in the first instance so we can try to resolve any concerns you have to hello@wellbeingtrustedcircle.com
We adhere to the principles relating to the Processing of Personal Data set out in GDPR which require Personal Data to be:
(a) Processed lawfully, fairly, and in a transparent manner (Lawfulness, Fairness and Transparency).
(b) Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
(c) Adequate, relevant, and limited to what is necessary about the purposes for which it is Processed (Data Minimisation).
(d) Accurate, and where necessary kept up to date (Accuracy).
(e) Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).
(f) Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction, or damage (Security, Integrity, and Confidentiality).
(g) Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
(h) Made available to individuals such as to allow them to exercise certain rights relating to their Personal Data (Data Subject’s Rights and Requests).
Why do we collect and process your Personal Data?
We collect and process your information for several purposes, depending on our relationship with you, and how the data was collected. For example:
· We may need to create a Contract and terms if you are a client
· If you are a candidate or we are representing you
· Where it is necessary due to a legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests
· Where we need to comply with a legal or regulatory obligation. Generally, we do not rely on consent as a legal ground for processing your Personal Data, other than when sending marketing communications to you via email or text message
· If you subscribe to our newsletter, or to receive our resources, services, or documents on an ad hoc basis
· If you visit our website to analyse usage to ensure what we offer is of interest to you
· To survey contacts about activity directly related to our marketing activity, service delivery or directly related projects undertaken by us
· To provide any services, training, consulting or coaching services to your Company, you personally, third party or employing company in line with client agreements made with the company
By providing your information to us through our website, or other means, we class this as legitimate interest in our services, and that of our partner organisations Reignite Purpose and Yellow Balloons coaching, and that you are happy for us to contact you in the future, and to share this with our relevant data sub-processors outlined below, so we can deliver our services to you.
How long will we keep your information?
There is some information that we must retain for set periods of time, in line with regulatory or legislative requirements. If this is not the case, we will keep your information until:
· You request for your data to be erased (see the section below) and this can be legally fulfilled
· The data is known to be or is suspected to be invalid/inaccurate
· The data is known to be or is suspected to be no longer appropriate for use for reasons of legitimate interest by us (as outlined above)
What to do if you wish to opt out of marketing material or you want your information to be amended or erased
If you believe any information held by us is incorrect and wish to amend it, please contact us in writing. Similarly, if you wish to opt out of receiving marketing material, contact us by email or post. Our details are at the bottom of this Privacy policy.
Should you receive marketing emails from us, you can also opt out by unsubscribing using the button at the bottom of any email.
Is your information shared with anyone else?
We do not share or sell on your data to any third party, other than to specific data sub-processors necessary for us to market and provide our service.
If we are working with you on a company or coaching basis, there may be a need to share your data with a third party for legal or other purposes, which will be discussed prior to being undertaken.
Our sub-processors are:
Katra:
Katra is an online system which we use to send out our newsletters, promotional materials and marketing-related communications to clients, prospective clients who have chosen to share their data us.
Microsoft:
We use Microsoft Office 365 to manage our emails and file storage, which may include some information that has been collected through our website or other sources relating to marketing and surveying activity. Microsoft has confirmed that they are DPA/GDPR compliant and have updated their terms and conditions to reflect this. Microsoft may transfer data outside of the EEA but will only do so in a manner that protects your data and meets the requirements of the GDPR and the Data Protection Act (2018).
Google:
We use Google Analytics and Google Tag Manager to monitor how you use the site to ensure that we can continue to provide you with the best possible experience online. Google may transfer data outside of the EEA but will only do so in a manner which protects your data and meets the requirements of the GDPR and the Data Protection Act (2018).
We may from time to time vary the platform or other storage areas such as Dropbox or other compliant software or database.
You have the right to withdraw consent to marketing at any time by emailing us at hello@wellbeingtrustedcicle.com
How do we store your data?
The information we collect is stored in secure cloud vaults that operate inside the EEA. All information is stored in an encrypted form. Information held by Microsoft on our behalf may be transferred outside of the EEA but only where there are appropriate protections in place and in line with GDPR guidance.
Cookies
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. You can set your browser not to accept cookies using the following instructions, although in a few cases some of our website features may not function as a result. You can configure cookie settings in your browser’s settings. Detailed step by step guidance on how to control and delete cookies is also available from www.aboutcookies.org
Other websites
Our website contains links to other websites. This privacy policy only applies to this website, or any platforms owned and managed by Wellbeing-Trusted Circle, so when you link to other websites you should read their privacy policies.
Changes to our Privacy Notice
We review and update our Privacy Policy every year. However, should there be major changes to legislation, or good practice, we will update on an ad hoc basis.
Getting in touch with us:
If you have any concerns, or queries regarding us or this policy, please get in touch:
Email: hello@wellbeingtrustedcircle.com
Tel: 0800 107 87 66
Post: Wellbeing-Trusted Circle Ltd - 51 High Street Mold Flintshire CH7 1BQ
Policy last reviewed: March 2025
Wellbeing – Trusted Circle Ltd