The Coaching Directory – PRIVACY POLICY
The Coaching Directory is committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with other applicable privacy laws.
This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.
In this Privacy Policy, “we” and “us” and “The Coaching Directory” means Carla Marie Egan (ABN 68 681 600 632) trading as ‘The Coaching Directory’. “You” refers to any individual about whom we collect personal information.
About The Coaching Directory
The Coaching Directory is an Australian based organisation committed to enabling optimum coaching outcomes. It does this by the compilation and management of an online coaching directory (Directory) which allows persons to find coaches that best meet their personal circumstances, requirements and objectives. The Coaching Directory also engages in the provision of services which are incidental and related to the Directory, including coach matching as well as referral services to coaches and coaching organisations.
What information does The Coaching Directory collect about you?
A. Website users, Directory coaches and prospective customers
When you use or enquire about our services (for example when you become a coach listed on the Directory or request a coach matching service) a record is made which includes your personal information.
The type of personal information that we collect will vary depending on the circumstances of collection and the kind of product or service that you request from us, but will typically include:
- full name;
- date of birth;
- email address;
- mobile or fixed line telephone number;
- address (for delivery and invoicing);
- the region or approximate location of a coach (for disclosure on their Directory profile);
- The Coaching Directory website password and login credentials;
- payment account details (The Coaching Directory will not store any credit card information as payments are managed by Stripe, a third party payments systems provider);
- customer insurance coverage details;
- information regarding our interactions and transactions with a customer (for example different services procured and event participation details);
- coaching services referral history;
- statistical Information about an individual’s online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical and website improvement purposes; and
- any additional personal information you provide to us, or authorise us to collect, as part of your interaction with The Coaching Directory.
B. Website and Directory users
Website and Directory users may be asked to provide personally identifiable information, particularly in circumstances where they engage with The Coaching Directory in order to procure products and services. In addition, The Coaching Directory may also collect the following and other such incidental information:
- full name
- email address
- details of a coaching participant’s employer where services are procured by that employer on behalf of the coaching participant;
- event, webinar, workshop or coaching course attendance details; and
- information we are required to collect which is mandated by law or at the direction of government health authorities (such as COVID -19 test information).
C. Prospective employees or applicants
We collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history. Generally, we will collect this information directly from you.
We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions.
D. Other individuals
The Coaching Directory may collect personal information about other individuals who are not customers of The Coaching Directory or website/Directory users. This includes customers and members of the public who participate in events (such as webinars, workshops and other in-person events) we are involved with, individual service providers, suppliers and contractors to The Coaching Directory, and other individuals who interact with The Coaching Directory on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with The Coaching Directory. Generally, it would include full name, email address and information regarding our interactions and transactions with you.
If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.
In limited circumstances, The Coaching Directory may collect information which is considered sensitive information. For example, if you are injured at an event promoted or delivered by The Coaching Directory we may collect health information about you in an emergency or otherwise with your consent.
We may collect personal information about children (for example, when children participate in events we are involved with). Where children do not have sufficient maturity and understanding to make decisions about their personal information, we will require their parents or guardians to make decisions on their behalf.
You can always decline to give The Coaching Directory any personal information we request, but that may mean we cannot provide you with some or all of the goods and/or services you have requested. If you have any concerns about personal information we have requested, please let us know.
How and why does The Coaching Directory collect and use your personal information?
The Coaching Directory collects personal information reasonably necessary to carry out our business, to assess and manage our customers’ needs, and provide services including delivery and maintenance of the website and the Directory. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you or third parties and managing customer relationships.
The purposes for which The Coaching Directory usually collects and uses personal information depends on the nature of your interaction with us, but may include:
- sale and delivery of goods and/or services to you;
- responding to requests for information and other general inquiries;
- managing, planning, advertising and administering programs, events and training;
- researching, developing and expanding our facilities, products and services offering;
- informing you of our activities, events, facilities, products and services;
- recruitment processes (including for volunteers, internships and work experience); and
- responding to enquiries and complaints.
The Coaching Directory generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example from:
- our affiliated and related companies; and
- third party suppliers and contractors who assist us to operate our business.
The Coaching Directory also collects and uses personal information for market research purposes and to innovate and improve our delivery of products and services, primarily the website and the Directory.
How does The Coaching Directory interact with you via the internet?
You may visit our website (https://thecoachingdirectory.com.au/) without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to The Coaching Directory will be managed in accordance with this Privacy Policy.
The Coaching Directory’s website uses cookies. A “cookie” is a small file stored on your computer’s browser, which assists in managing customised settings of the website and delivering content. We may collect certain information such as your device type, browser type, IP address, pages you have accessed on our websites (such as coach profiles you have reviewed and video content viewed) and on third-party websites. You are not identifiable from such information.
You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.
The Coaching Directory’s websites may contain links to third-party websites. The Coaching Directory is not responsible for the content or privacy practices of websites that are linked to our website. In particular, any content or interactions occurring on sites belonging to and managed by coaches listed on the Directory are the responsibility of that particular coach and you should refer to their particular privacy policy in relation to such interactions.
Can you deal with The Coaching Directory anonymously?
The Coaching Directory may provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry via the website or simply viewing coach profiles or content). Generally, it is not practicable for The Coaching Directory to deal with coaches on the Directory (or other customers) anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services, buy goods from us or participate in our events, programs or activities we manage or deliver. For example, offering coaching services anonymously on the Directory or from the website is not permitted.
How does The Coaching Directory hold information?
The Coaching Directory stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.
As a business committed to sustainability, the Coaching Directory endeavours not to print or manage hard copy, paper based documents and maintains physical security over any electronic data stores it holds at its premises, such as through locks and security systems. We also maintain computer and network security, for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems.
Our website does not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our website are encouraged to exercise care in sending personal information via the internet.
From time to time, we take steps to destroy or de-identify information that we no longer require.
Does The Coaching Directory use or disclose your personal information for direct marketing?
The Coaching Directory may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.
If you opt-out of receiving marketing material from us, The Coaching Directory may still contact you in relation to its ongoing relationship with you for example, any problems with your Directory listing, website account or a coaching referral.
How does The Coaching Directory use and disclose personal information?
- For Directory coaches
If you are a Directory coach, customer or participant in an event, we may disclose your limited personal information, photos and other content (for example for display on the Directory) to website users to enable them to directly procure your services. We may also provide limited information about you to venues where this is reasonably necessary for, and relevant to, the delivery of an event we organise or are involved in. At such events, we may use images or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur. We may also collect information where mandated by law or direction of government health authorities.
- For customers and website users
The purposes for which we may use and disclose your personal information will depend on the services we are providing to you. For example, viewers of the Directory and general users of the website will have limited information about them shared with other users with whom they interact. If you have engaged us to provide goods or deliver a service, we may disclose information about you to service providers where this is relevant to our services (for example couriers and parcel delivery providers).
- Disclosure to contractors and other service providers
The Coaching Directory may disclose information to third parties we engage in order to maintain the Directory and the website and provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research.
Personal information may also be shared between related and affiliated companies of The Coaching Directory, located in Australia.
Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.
- Use and disclosure for administration and management
The Coaching Directory will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:
- administering billing and payments and debt recovery;
- planning, managing, monitoring and evaluating our services;
- quality improvement activities;
- statistical analysis and reporting;
- training staff, contractors and other workers;
- risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
- responding to enquiries and complaints regarding the Directory, the website or our services;
- obtaining advice from consultants and other professional advisers; and
- responding to subpoenas and other legal orders and obligations.
- Other uses and disclosures
There are some circumstances in which we must disclose personal information, for example:
- where we reasonably believe that an individual listed on the Directory or a user on the website may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;
- as required by any law (including the Privacy Act 1988 (Cth)); and/or
- in order to sell our business (in that we may need to transfer personal information we hold to a new owner).
We may use and disclose your personal information for other purposes explained at the time of collection or otherwise as set out in this Privacy Policy.
Does The Coaching Directory disclose your personal information overseas?
Whilst The Coaching Directory is an Australian organisation, it works with customers, service providers, sponsors and commercial interests that may be based overseas. It is possible that your personal information may be disclosed to overseas recipients.
Unless we have your consent, or an exception under the Australian Privacy Principles applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information.
We will not disclose an individual’s Personal Information to any entity outside of Australia that is in a jurisdiction that does not have a similar regime to the Australian Privacy Principles or an implemented and enforceable privacy policy similar to this Privacy Policy. We will take reasonable steps to ensure that any disclosure to an entity outside of Australia will not be made until that entity has agreed to safeguard Personal Information as we do.
How can you access or seek correction of your personal information?
You are entitled to access your personal information held by The Coaching Directory on request. To request access to your personal information please contact our privacy officer using the contact details set out below.
You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
What should you do if you have a complaint about the handling of your personal information?
You may contact The Coaching Directory at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.
You may make a complaint about privacy to the privacy officer at the contact details set out below.
The privacy officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond on a preliminary basis to your complaint within a week.
If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and seek to resolve a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are not satisfied with our response to your complaint, or you consider that The Coaching Directory may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.
How changes are made to this Privacy Policy?
The Coaching Directory may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes.
How can you contact The Coaching Directory?
For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:
The Coaching Directory Privacy Officer
PO Box 205, Aireys Inlet VIC 3231, Australia
Email: connect@thecoachingdirectory.com.au
This Privacy Policy was last updated in October 2021
