This page explains the personal information I collect, use and hold when you work with me and when you visit this website.

Using the services

When you contact me by e-mail I will have your name, e-mail address and any other information included in the e-mail message.

For corporate clients: in providing the privacy and plain English services I am unlikely to process any personal information that you are a data controller for, such as user or customer data. The only employee data I am likely to process will be contact details of relevant staff that I am working with.

As part of the coaching services I will keep session notes on what we discussed, any tools or activities we use, and any action points. You may choose to disclose sensitive information during the coaching sessions.

I only keep information for as long as it is necessary to provide the services, for my own accounts and records, or to meet legal obligations.

I only use your personal information to:

• reply to your e-mails;

• provide the services;

• communicate with you about privacy, plain English editing or training, or coaching services you have asked for;

• issue and communicate with you about payment and invoices; and

• maintain accounts and records.

If you are happy with my work, I may ask you to provide a client review for this website. This will only include your name and / or organisation if you want it to.

Information sharing

I use the service providers listed below to help run my business. The agreements in place include obligations on the service providers to safeguard your information.

I will share information with relevant authorities if I am legally required to, for example, if I receive a court order.

Coaching: as well as the above, I may need to share information where there are threats of harm or illegal activity, or for supervision and assessment as part of my training. There are more details in the coaching agreement and I will cover this in our first call.

Your rights

You can ask me for a copy of all the information I hold about you (access right).

You can also update any of your information that is inaccurate (correction right).

You have rights to:

• request I delete your information;

• object to what I do with your information; and

• ask me to restrict what I do with your information.

These rights can be complicated, and don’t apply to all information in all circumstances.

You also have the right to get back information you have provided me electronically, and to have it transferred directly to another organisation, if this is feasible (portability right). However, as this is not likely to be feasible, and this right provides you with less information than the access right, you are better off making an access request.

You can learn more about your rights and complain to the CNIL here: https://cnil.fr/fr/adresser-une-plainte

Legal information

Data controller: Emma Butler EI, trading as Creative Elephant. Sub-trading names: Creative Privacy, Creative Clarity, Creative Coaching.

Lawful bases: performance of a contract; legitimate interests; legal obligation; consent (website reviews, sensitive data disclosed in coaching sessions).

Accounts and records retention: 7 years from the end of the last company financial year they relate to.

Service providers: Google Workspace; Indy (business bank account and accounting software); Calendly (meeting planner); Yoti Sign (contract signing); Toggl (time recording).

Transfers: some service providers store data in other countries; in these cases transfer safeguards (standard contract clauses) are in place.

Contact

Please contact me for any questions or to make a rights request.