Privacy Policy Notice

By providing information on this website your are agreeing that you are over 18 years of age.

What we do with your data:

In this statement we set out how marissamccallam.com uses and protects any information that you give us when you use our website. marissamccallam.com is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using our website, then you can be assured that it will only be used in accordance with this statement. marissamccallam.com may change this policy from time to time by updating this document. You can request this policy at any time to check that you are happy with any changes. This policy is effective from 26th July 2020.

What we do with the information we gather:

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
Internal record keeping.
We may use the information to improve our products and services.
We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.

Security:

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Controlling your personal information:

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by emailing us at marissa@marissamccallam.com

We will not sell, distribute or lease your personal information to third parties unless we are required by law to do so. You may request details of personal information which we hold about you under the Data Protection Act 1998. If you would like a copy of the information held on you email us at marissa@marissamccallam.com

If you believe that any information we are holding on you is incorrect or incomplete, please email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.

The Data Controller

marissamccallam.com may process personal data relating to participants and practitioners and therefore is a data controller.

marissamccallam.com has voluntarily registered with the ICO (registration reference: ZA773428) and will renew this registration annually or as otherwise legally required.

Roles and responsibilities

This policy applies to marissamccallam.com’s Founder, Marissa McCallam, a fully qualified, insured Coach, Exercise to Music and Kickboxercise Instructor.

Marissa McCallam is also the first point of contact for individuals whose data marissamccallam.com processes, and for the ICO. Marissa McCallam is contactable via email – marissa@marissamccallam.com

Marissa McCallam will ensure all individuals acting on behalf of marissamccallam.com collect, store and process any personal data in accordance with this policy.

Data protection principles

The GDPR is based on data protection principles that marissamccallam.com must comply with.

The principles say that personal data must be:

Processed lawfully, fairly and in a transparent manner.
Collected for specified, explicit and legitimate purposes.
Adequate, relevant and limited to what is necessary to fulfil the purposes for which it is processed.
Accurate and, where necessary, kept up to date.
Kept for no longer than is necessary for the purposes for which it is processed.
Processed in a way that ensures it is appropriately secure.

This policy sets out how marissamccallam.com aims to comply with these principles.

Collecting personal data

Lawfulness, fairness and transparency

marissamccallam.com will only process personal data where we have one of 6 ‘lawful bases’ (legal reasons) to do so under data protection law:

The data needs to be processed so that marissamccallam.com can fulfil a contract with the individual, or the individual has asked Marissa McCallam to take specific steps before entering into a contract.

The data needs to be processed so that marissamccallam.com can comply with a legal obligation.
The data needs to be processed to ensure the vital interests of the individual e.g. to protect someone’s life.
The data needs to be processed so that marissamccallam.com can perform a task in the public interest.
The data needs to be processed for the legitimate interests of marissamccallam.com or a third party (provided the individual’s rights and freedoms are not overridden)

The individual has freely given clear consent.

For special categories of personal data, marissamccallam.com will also meet one of the special category conditions for processing which are set out in the GDPR and Data Protection Act 2018.

Whenever marissamccallam.com first collect personal data directly from individuals, we will provide them with the relevant information required by data protection law.

Limitation, minimisation and accuracy

marissamccallam.com will only collect personal data for specified, explicit and legitimate reasons. We will explain these reasons to the individuals when we first collect their data.

If marissamccallam.com want to use personal data for reasons other than those given when we first obtained it, we will inform the individuals concerned before we do so, and seek consent where necessary.

When marissamccallam.com no longer need the personal data held, we will ensure it is deleted or anonymised.

Sharing personal data

marissamccallam.com will not normally share personal data with anyone else, other than law enforcement and government bodies where we are legally required to do so, including for:

The prevention or detection of crime and/or fraud.
The apprehension or prosecution of offenders.
The assessment or collection of tax owed to HMRC.
In connection with legal proceedings.
Where the disclosure is required to satisfy our safeguarding obligations.
Research and statistical purposes, as long as personal data is sufficiently anonymised or consent has been provided.

We may also share personal data with emergency services and local authorities to help them to respond to an emergency situation that affects any of our clients.

Where we transfer personal data to a country or territory outside the European Economic Area, we will do so in accordance with data protection law.

Subject access requests and other rights of individuals

Subject access requests

Individuals have a right to make a ‘subject access request’ to gain access to personal information that marissamccallam.com holds about them. This includes:

Confirmation that their personal data is being processed
Access to a copy of the data
The purposes of the data processing
The categories of personal data concerned
Who the data has been, or will be, shared with
How long the data will be stored for, or if this isn’t possible, the criteria used to determine this period
The source of the data, if not the individual
Whether any automated decision-making is being applied to their data, and what the significance and consequences of this might be for the individual

Subject access requests must be submitted in writing, either by letter or email to Marissa McCallam. They should include:

Name of individual
Correspondence address
Contact number and email address
Details of the information requested

Responding to subject access requests

When responding to requests, marissamccallam.com:

May ask the individual to provide 2 forms of identification.
May contact the individual via phone to confirm the request was made.
Will respond without delay and within 1 month of receipt of the request.
Will provide the information free of charge.
May tell the individual we will comply within 3 months of receipt of the request, where a request is complex or numerous. We will inform the individual of this within 1 month, and explain why the extension is necessary.

If the request is unfounded or excessive, marissamccallam.com may refuse to act on it, or charge a reasonable fee which takes into account administrative costs.

A request will be deemed to be unfounded or excessive if it is repetitive, or asks for further copies of the same information.

When marissamccallam.com refuse a request, we will tell the individual why, and tell them they have the right to complain to the ICO.

Other data protection rights of the individual

In addition to the right to make a subject access request (see above), and to receive information when marissamccallam.com are collecting their data about how we use and process it, individuals also have the right to:

Withdraw their consent to processing at any time
Ask marissamccallam.com to rectify, erase or restrict processing of their personal data, or object to the processing of it (in certain circumstances)
Prevent use of their personal data for direct marketing
Challenge processing which has been justified on the basis of public interest
Request a copy of agreements under which their personal data is transferred outside of the European Economic Area
Object to decisions based solely on automated decision making or profiling (decisions taken with no human involvement, that might negatively affect them)
Prevent processing that is likely to cause damage or distress
Be notified of a data breach in certain circumstances
Make a complaint to the ICO
Ask for their personal data to be transferred to a third party in a structured, commonly used and machine-readable format (in certain circumstances)

Individuals should submit any request to exercise these rights to Marissa McCallam.

Photographs and videos

As part of marissamccallam.com's activities, we may take photographs and record images of individuals.

marissamccallam.com request consent for marketing and promotional materials prior to activity commencement.

Uses may include:

Promotional brochures, flyers, posters, etc.
Outside of marissamccallam.com by external agencies such as newspapers or magazines
Online on marissamccallam.com’s website or social media pages

Consent can be refused or withdrawn at any time. If consent is withdrawn, we will delete the photograph or video and not distribute it further.

Data protection by design and default

marissamccallam.com will put measures in place to show that we have integrated data protection into all of our data processing activities, including:

Only processing personal data that is necessary for each specific purpose of processing, and always in line with the data protection principles set out in relevant data protection law.
Completing privacy impact assessments where marissamccallam.com’s processing of personal data presents a high risk to rights and freedoms of individuals, and when introducing new technologies.
Integrating data protection into internal documents including this policy, any related policies and privacy notices.
Regularly undertaking training on data protection law, this policy, any related policies and any other data protection matters; we will also keep a record of such training.
Maintaining records of our processing activities, including: For all personal data that we hold, maintaining an internal record of the type of data, data subject, how and why we are using the data, any third-party recipients, how and why we are storing the data, retention periods and how we are keeping the data secure.

Data security and storage of records

We will protect personal data and keep it safe from unauthorised or unlawful access, alteration, processing or disclosure, and against accidental or unlawful loss, destruction or damage.

In particular:

Paper-based records and portable electronic devices, such as laptops and iPads that contain personal data are kept under lock and key when not in use.
Papers containing confidential personal data must not be left anywhere where there is general access
Where marissamccallam.com store personal information on their personal devices they follow sensible security procedures, such as strong passwords.
Where we need to share personal data with a third party, we carry out due diligence and take reasonable steps to ensure it is stored securely and adequately protected.

Disposal of records

Personal data that is no longer needed will be disposed of securely. Personal data that has become inaccurate or out of date will also be disposed of securely, where we cannot or do not need to rectify or update it.

For example, we will shred or incinerate paper-based records, and overwrite or delete electronic files.

Personal data breaches

marissamccallam.com will make all reasonable endeavours to ensure that there are no personal data breaches.

In the unlikely event of a suspected data breach, we will report the data breach to the ICO within 72 hours when appropriate.

Monitoring arrangements

The policy will be reviewed annually, or in the following circumstances:

changes in legislation and/or government guidance
as a result of any other significant change or event.