Privacy statement

0. Glossary of terms

1. In this privacy statement, the following terms shall have the following meanings:

  • Contractor: the independent coach associated with LemongrassCoaching;
  • Client: an employer or private individual awarding a contract to the contractor;
  • Assignment: the agreement between the contractor and the customer;
  • Proposal: description of proposed services by the contractor for the benefit of the client;
  • Candidate: the natural person accompanied by the contractor.

1. Controller

The Contractor is a data controller under the AVG.

2. Obtaining data:

The contractor obtains data from the client and/or candidate in the online application form, by e-mail or in a personal interview when orientating and possibly entering into and performing the assignment. Data may also be obtained because third parties refer the client or candidate to the Contractor.

3. Data processed

The Contractor processes (potentially) the following personal data or personal/confidential data from candidates and clients:

  • NAW data (name - address - place of residence)
  • Contact details (phone number(s), e-mail address(es))
  • Date and place of birth, passport photograph, work experience, competences (CV)
  • All information made available by the client and/or candidate prior to and during the provision of services, including detailed career and/or coaching assignments, which may contain personal or sensitive information, e.g. on health.
  • Interview notes (for own use only) recorded by the contractor prior to, during and after the performance of assignments for his own use.
  • Returned evaluation forms

4. Basis and purposes

a. The contractor processes the above data to be able to execute the client's assignments.
b. Purposes of registration are:

  • Provide professional services;
  • Efficiency and cost control in required services
  • Maintaining contact during and - if required - after the provision of services;
  • Customer database management;
  • Planning and organising work;
  • (Tax) administration and billing;
  • Be able to answer substantive questions from candidate/client (including after completion of services);
  • Be able to efficiently flesh out a follow-up assignment if required;
  • Improve services;
  • Compliance with legal obligations.

5. Statement of consent

a. Upon entering into the assignment, the client and candidate will be made aware of the general terms and conditions of which this privacy regulation is a part and will be alerted to this privacy regulation.
b. If (parts of) the registration raise objections, specific agreements can be made between the client, candidate and the contractor about an alternative registration, to be laid down in the assignment - provided that the contractor can thereby comply with the legal obligations and is not hindered in the professional performance of the assignment.

6. Mode of storage and security

a. The Contractor stores the data mentioned under 3 in:

  • Paper files, kept locked in a filing cabinet;
  • Digitally on a password-protected laptop and in the secure 'cloud' environment;
  • On a password-protected mobile phone.

b. The Contractor is alert to privacy breaches and uses appropriate security measures.

7. Disclosure to third parties

a. The contractor will not provide any personal or confidential data of candidate to the client or vice versa without the explicit consent of the person(s) concerned.
b. If necessary for the security or use of systems and external services (such as for computer management or when deploying a test platform), data will be provided or access to data may be granted to external service providers. These third parties may only process the relevant data for these purposes and within the legal frameworks.
c. If there is contact via social media (including LinkedIn and Facebook), data may be stored by these parties, this within the applicable European privacy legislation.

8. Retention periods

a. The registered data will not be kept longer than necessary for the proper execution of the assignment and the purposes mentioned in this declaration under article 4. Usually, for the file, this will be two years after the last contact; for fiscally required data, the retention period is 7 years.
b. The recorded data will be adequately destroyed after the retention period mentioned under a has expired.

9. Cookies

Functional cookies are used on the website to improve online services.

10. Rights

a. The contractor and/or candidate may request information from the contractor regarding the registered data.
b. In view of strict confidentiality and the necessary freedom in professional practice, it is not possible to view personal notes or have them transferred.
c. The consent mentioned in paragraph 5 can be withdrawn upon request - a request can be submitted by e-mail to the relevant coach of LemongrassCoaching.
d. Recorded personal data may be destroyed at the request of the person concerned before the expiry of the two-year period, provided this is permitted by law and the data are not required for the settlement of any dispute. A request may be submitted by e-mail to the relevant coach of LemonGrass Coaching.

11. Changes

This privacy regulation may be amended in response to new regulations or to achieve better interpretation.