Privacy Notice

Privacy Notice

This Privacy Notice explains how The Improvement Coalition CIC collects, stores, manages,

and protects your personal data. It outlines the types of data that we hold and how we use them.

The Improvement Coalition CIC takes its responsibilities around the correct collection, use and destruction of the personal data of its stakeholders very seriously and is committed to openness and fairness in the handling of Personal Data. We aim to be clear when we collect information about you and not do anything you wouldn’t reasonably expect.

The Improvement Coalition CIC is the Data Controller (as defined by the Data Protection Act 2018 and all applicable laws which replace or amend it) who will collect and process your personal data.

This policy explains how we collect, use, and share your personal information. It covers:

1. Who we are

2. What information do we collect about you?

3. How do we collect the data?

4. Cookies

5. How will we use your information?

6. Marketing communications

7. Your rights relating to your personal data

8. How to contact us to raise a concern or complaint

9. Future changes

The Improvement Coalition CIC is a limited company (company no. 15540415). Our registered address is 86-90 Paul St, London, EC2A 4NE.

Our aim is to provide high-quality specialist support to individuals and organisations on quality improvement and leadership in health and care. We also work with organisations in support of strengthening their approaches to improvement, leadership and professional advocacy. 

The Improvement Coalition CIC collects and processes personal data to deliver commissioned projects and programme of work. In support of our work we may collect and process some or all the following data about stakeholders:

• Name, title and gender
• Contact details including postal address, personal email, work email, phone number and links to social media accounts
• Personal photo and video of events• Occupation, career history, professional qualifications, CV
• Records of communications sent to you by us and received from you by us
• Website use, including IP address and any interactions with this website and other online pages managed by us.

We do not capture sensitive categories of data, such as race, religion and ethnicity.

You may withdraw your consent for us to process the above information at any stage though we may already have disposed of the information.

Most of the information we process is obtained directly from you and organisations you work for. We may also collect information from publicly available sources to keep your information up to date. We will also obtain your information when we use cookies on our websites (see below). We may also obtain your personal data through your use of social media such as X (previously Twitter) or LinkedIn depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.

View LinkedIn's privacy policy 

View X's privacy policy 

Cookies are small text files that websites use to store information about things like user preferences.

We use cookies on this website to:

• help make the website easier to use for people with a website account
• help people share our content via social media
• help us understand how the site is being used so that we can identify areas that are working well and areas that need improvement.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

For more information about cookies, visit the All About Cookies website. 

We use the information you give us to:

• correspond with you around any projects, programmes or other work that you are involved in, in any capacity
• seek your feedback, comments and other insights to help us evaluate, learn and better understand the impact of our work
• provide you with the services and the information about our activities and events that you have requested
• conduct surveys and process your response to any survey you participate in for research, evaluation and statistical purposes
• to undertake bid work or other activities in support of business development and sales
• otherwise communicate with you regarding our aims and activities
• ensure we do not send unwanted information to stakeholders who have informed us they do not wish to be contacted
• keep your data up to date
• use IP addresses to identify the location of users, to block disruptive use and to establish the number of visits from different countries
• for internal record keeping to keep a record of your relationship with us.

The Improvement Coalition CIC will only contact you for marketing purposes, for example to keep you up to date on our work, where we have your consent, or we are otherwise allowed to do so. We will make it easy for you to tell us if you would like to receive communications from us and hear more about our work and the ways in which you would like to receive this information such as email, newsletter, or post.

We will not send you marketing material or communications if you tell us that you do not wish to receive it. There are a variety of ways you can do this, and these are detailed below.

Where you give us your consent to send you marketing information, you may opt out of this at any time. We review our retention periods for personal information on a regular basis, and we frequently encourage you to update your preferences, so you only receive news and opportunities you would like to hear about. You can update or withdraw your consent at any time.

'Soft opt in'

This allows organisations to send communications by email to individuals, who we have an existing relationship with, and where we have identified that we have a legitimate interest in communicating about The Improvement Coalition CIC, provided they are given the opportunity to opt out at the time of initial communication or engagement. This may be where you have collaborated with us, or participated in one of our programme or projects.

How to control what we send you or request we update your personal information?

The accuracy of your information is important to us. We want to ensure that we are able to communicate with you in ways that you are happy with, and to provide you with information that is of interest.If you wish to change how we communicate with you, or update the information we hold, then please contact us:

• email us at sid@improvementcoalition.org.uk
• write to us at: Data Protection Officer, The Improvement Coalition CIC, 86-90 Paul St, London, EC2A 4NE

How long will it take for these changes to be effective?

We endeavour to make updates to the marketing preference within 5 business days from receipt of email or letter.

Who do we share your information with and why?

The Improvement Coalition CIC will only use the information within the organisation for the purposes for which it was obtained. We will not, under any circumstances, share or sell your data with any third party for their own purposes, and you will not receive marketing from any other companies, charities, or organisations as a result of giving your details to us.

We may share your information with:

• Third parties who supply services to us or process information on our behalf such as our website developer, event organisers and publishers.
• Assessors, auditors and regulators as required by legal obligation or internal governance
• These “data processors” will only act under our instruction and are subject to contractual obligations containing strict data protection clauses. We do not allow these organisations to use your data for their own purposes or disclose it to other third parties without our consent and we will take all reasonable care to ensure that they keep your data secure.

We will share your information if we are required to by law (for example to law enforcement

agencies for the prevention or detection of crime, subject to such bodies providing us with a

relevant request in writing).

Where do we keep your data?

The Improvement Coalition CIC maintains all your data within the United Kingdom (UK) or the European Economic Area (EEA).

Data is only processed by third parties outside of the UK or EEA for the provision of services such as:

• managing events outside of the UK or EEA
• technical service support
• order fulfilment outside of the UK or EEA

Where data is processed outside of the UK or EEA we have verified that appropriate safeguards are in place including:

• Complying with all data protection principles
• Where possible trying to ensure data is processed in a country that is on the list of countries approved as adequate by the UK government

Any transfers of information originating from within the UK or EEA to countries outside the UK or EEA will normally be made on the basis of the standard contractual clauses (SCCs)

How long do we keep your data?

We will hold your personal data in our systems for as long as is necessary for the relevant activity. These purposes are laid out in the section 'How we will use your information'.

Financial records will be retained in line with financial law and regulation for at least seven years. 

If you request that we stop sending you marketing materials we will keep a record of your contact details to enable us to comply with your request not to be contacted.

How do we protect your data?

We ensure that there are appropriate and operational measures in place to protect your personal data.

We have appropriate technical controls in place to protect your personal data:

• Our network is protected behind firewalls
• Anti virus and Malware software is deployed
• All systems are password protected
• Mobile and removable devices are encrypted

We have appropriate operational measures in place to protect your personal data:

• We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff and contractors.
• Where we use external companies to collect or process personal data on our behalf, we do comprehensive checks on these companies before we work with them, and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal data they collect on our behalf, or have access to.
• We have a robust audit framework in place to ensure internal and external measures and obligations are in place and being maintained.

There are specific rights enshrined in law that you have around your data. 

These rights are:

i. Informed – you have the right to be informed about what data we hold and for what purpose

ii. Access – you have the right to have access to your personal data

iii. Rectification – you have the right to have your personal data corrected or removed if it is inaccurate

iv. Erasure – you have the right to have your personal data deleted from our systems

v. Restrict processing – you have the right to restrict the processing of your personal data

vi. Right of objection – you have the right to object to the processing of your personal data for communications and marketing

vii. Portability – you have the right to have your personal data transferred

viii. Withdraw consent – where you have provided consent to process your personal data you have the right to withdraw that consent at any time

ix. Complain – you have the right to complain to the regulator and/or seek judicial remedy if your data has not been treated in accordance with the law

We will respond to you within one month of receiving a request related to anyone of the above rights unless the number and complexity of the requests made is deemed sufficiently high in which case, we may extend this time by a further two months. We will inform you if we need to make use of this additional time and why we need to do so.

If you disagree with our approach you may raise your concerns with the Information Commissioner’s Office (ICO)

To assist us in responding to these requests, we may ask you to verify your identity to make sure we do not give your personal data to the wrong person, update your data with details you did not provide or take action you did not request.

i. Right to be Informed

The Improvement Coalition CIC has published this Privacy Notice along with additional notices when we collect personal data from you to explain what personal data we collect and process. We aim to be as open and transparent as possible about how we use your personal data.

ii. Right of Access

You have the right to request a copy of the personal information that we hold about you. If you would like a copy of some or all of your personal data please contact us providing full details of your request, using the contact information outlined in section 8. 

iii. Right of Rectification

It is important to us that the information we hold about you is accurate and up to date. If you believe that the information we hold is inaccurate or incomplete you have the right to ask us to rectify it. If we have passed your data to a third party for processing then we will also contact them to rectify the data. To request the rectification of your data please contact us providing full details of your request, using the contact information outlined in section 8. 

iv. Right of Erasure

This is sometimes referred to as the “Right to be forgotten”. You can request that we delete your personal data from our systems if you:

• Believe the data is no longer necessary for the purpose for which it was collected
• Withdraw your consent (subject to the requirement for us to retain data to process your request)
• Believe we have processed your data unlawfully
• Believe we should delete your data to comply with other laws or regulationWe may choose to refuse your request if we believe:
• We have a legal obligation to keep your data
• It is required for the legitimate interests and purposes of our business
• It is required for the establishment, exercise or defence of legal claims

To request the erasure of your data please contact us providing full details of your request, using the contact information outlined in section 8. 

v. Right of Restriction

You have the right to ask The Improvement Coalition CIC to restrict how we process your data. This provides for a temporary halt to processing your data. You may make the request if you believe that:

• We should not process your data whilst we are in discussions with you regarding a disagreement over the accuracy of your personal data, or;
• We have processed your data in a manner you believe to be unlawful but rather than asking for the erasure of the data you would prefer another course of action to rectify your issue, or;
• We no longer require the data but you do not wish us to dispose of it as you require it to establish or defend a legal claim

If such as restriction is put in place we shall limit the processing of your data to storage with the following exceptions

• Where the processing is for the establishment, exercise or defence of legal claims
• We must process it to protect the rights of another person

To request the restriction of processing of your data please contact us providing full details of your request, using the contact information outlined in section 8. 

vi. Right of Objection

You have the right to object to the processing of your personal data. If your data is being used for direct marketing purposes you have the right at any time to stop us from contacting you as outlined in this notice. If we are processing your data for research or statistical purposes or processing your data based on our legitimate interests you may seek  to object to the processing of your personal data.

We may reject your request

• Where we are processing data for research and statistical purposes where there is a public interest in the continued processing of the data
• Where we believe we have compelling legitimate grounds for continuing to process your data which outweighs any harm or damage to you through the continued processing of the data
• Where the processing is for the establishment, exercise or defence of legal claims

To object to the processing of your data please contact us providing full details of your request, using the contact information outlined in section 8. 

vii. Right of Portability

The Improvement Coalition CIC must allow you to obtain and reuse your personal data for your own purposes. This applies to personal data you have provided to us and is processed in our computer systems. You can request that we provide you with a copy of this data in a format that can be read by another person’s or organisation’s computer system.

You have the right to transfer that copy of your data to another organisation or request that we do it for you where it is technically feasible for us to do so. This right of transfer can be refused where we feel it may adversely affect the rights of another person.

To request the transfer of your data please contact us providing full details of your request, using the contact information outlined in section 8. 

viii. Right to withdraw consent

Where we rely on your consent for the processing of your data you have the right to change your mind and withdraw your consent at any time. If you withdraw your consent we must stop processing your data.

To withdraw your consent for processing your data please contact us providing full details of your request, using the contact information outlined in section 8. 

ix. Right to Complain

You have a right to complain to the Information Commissioner’s Office (ICO) if:

• We do not act on your request within one month of receipt and do not provide you with reasons why.
• You believe that the way we are processing your data is not in keeping with the requirements of the law
• You believe your rights have been infringed because of the way we have processed your data

Please see the following section 8 for contact information.

Contacting The Improvement Coalition CIC

If you have any concerns about how your personal data is being collected and processed, or wish to exercise any of your rights detailed in this Privacy Notice please contact:

Data Protection Officer

The Improvement Coalition CIC

86-90 Paul St,

London

EC2A 4NE

Email: sid@improvementcoalition.org.uk

Contacting the Information Commissioner’s Office

If you have wider concerns about how The Improvement Coalition CIC manages information or wish to make a complaint please contact the Information Commissioners Office (ICO). 

Concerns can also be logged via the ICO website 

If our information practices change at some point in the future we will update this policy. If material changes are made to this notice we will notify you by placing a prominent notice on the website and where we communicate with you through digital media.

We keep our Privacy Notice under regular review.