1. Who we are
HTGA is the controller of the personal information described in this notice. Privacy contact: admin@htga.co.uk.
2. Information we collect
We may collect names, contact details, age or candidate stage, parent or guardian details, education and employment history, target roles, application materials, session notes, correspondence, payment and transaction records, technical website data, consent records, complaints and feedback.
Please do not provide health, disability, ethnicity, religious belief or other sensitive information unless it is genuinely relevant and you are comfortable doing so. Where needed, we will identify an appropriate lawful condition for processing it.
3. How we obtain information
Information is obtained directly from Clients and candidates through enquiries, consultations, forms, email, messaging, sessions and submitted documents. We may also receive information from a parent, guardian or referrer, and limited technical information from our website, scheduling, payment and communications providers.
4. Why we use information and lawful bases
We use information to respond to enquiries, assess suitability, enter into and perform contracts, personalise coaching, administer sessions and payments, keep business records, protect our services, handle complaints and comply with law.
Our principal lawful bases are steps at your request before entering a contract, performance of a contract, legal obligation and legitimate interests in operating and improving a safe, effective service. We rely on consent where the law requires it, including some marketing, testimonials and certain sensitive information.
5. Marketing
We may send service related communications necessary to administer an enquiry or contract. Promotional email or electronic marketing will only be sent where permitted by law. You can unsubscribe at any time without affecting service communications.
6. Children and parent involvement
Where a candidate is under 18, we ordinarily contract with and communicate through a parent or legal guardian while respecting the candidate’s privacy and participation. We collect only information reasonably required for the service and safeguarding.
7. Sharing information
We may share information with trusted providers for website hosting, email, cloud storage, scheduling, video meetings, customer management, accounting, payment processing and professional advice. Providers may only use information for authorised purposes and must protect it appropriately.
We do not sell personal information. We may disclose information where required by law, to protect rights or safety, or in connection with a genuine business reorganisation subject to appropriate safeguards.
8. International transfers
Some service providers may process information outside the UK. Where this occurs, we will use an approved transfer mechanism or another lawful safeguard and assess the protection provided.
9. Retention
Enquiry records are normally retained for up to 24 months after the last meaningful contact. Client files, contracts, payment and core service records are normally retained for up to 6 years after the relationship ends for legal, tax and dispute purposes. Routine coaching drafts and recordings, where used, should be deleted sooner when no longer needed.
Actual periods may be adjusted where law, safeguarding, a dispute or the Client’s request justifies a different period.
10. Security
We use proportionate organisational and technical measures, including access controls, account security, trusted providers, backups and data minimisation. No internet system is completely secure, but suspected breaches are assessed and reported where legally required.
11. Your rights
Depending on the circumstances, you may have rights to be informed, access your information, correct it, erase it, restrict or object to processing, receive portable data and withdraw consent. You may also object to direct marketing at any time.
Requests should be sent to the privacy contact above. We may need to verify identity and may lawfully refuse or limit a request in certain circumstances.
12. Cookies and analytics
HTGA is committed to respecting your privacy. At present, the website uses only essential cookies required for its operation. Should we introduce optional features that require additional cookies, we will update this notice and seek your consent where required.
13. Complaints and updates
Please raise privacy concerns with us first. You also have the right to complain to the UK Information Commissioner’s Office. We may update this notice when our services, providers or legal duties change.