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Privacy Policy

Good Access – Customer Privacy Notice 

Registered name: Valentina Group Ltd
Trading name: The Good Consulting Company
Registered office: Flat 2, 36 Lesbourne Road, Reigate, Surrey, RH2 7LD, UK 

We are the controller of your personal data. This privacy notice explains what personal information we collect, how we use it, and your rights. 

Contact details 

Post:
Valentina Group Ltd
Flat 2, 36 Lesbourne Road
Reigate
Surrey
RH2 7LD
United Kingdom 

Telephone: 07549 067770
Email: heike@valentinagroup.co.uk 

What information we collect, use, and why

1. To provide and improve our services (training, consultation, coaching, accessibility work)

We collect and use: 

  • Names and contact details 
  • Pronoun preferences 
  • Employer, role and organisation details 
  • Addresses (where relevant for billing or in-person work) 
  • Session details (bookings, attendance, certificates, feedback) 
  • Communication preferences 
  • Payment and transaction data (amounts, dates, invoices, services purchased) 
  • Usage data (for example how you interact with our website, emails or online sessions) 
  • Records of meetings and decisions (for example coaching notes, agreed actions, training outcomes) 
  • Correspondence (emails, messages and notes of conversations) 

Special category (sensitive) information 

Because our work focuses on disability, neurodivergence and inclusion, we may also collect: 

  • Health and disability information (including neurodivergence, access needs, communication preferences, medication impacts where you choose to share this) 
  • Information about how your health or disability affects you at work or in daily life 
  • Equality monitoring data (such as race/ethnicity or religion/belief) – only if you choose to provide it and only where relevant 

We use this information to: 

  • Arrange and deliver training, coaching, workshops and consultations 
  • Tailor support to individual goals and needs 
  • Provide accessible, trauma-informed and inclusive sessions 
  • Issue certificates, reports and training records 
  • Monitor quality and improve our services over time 
  • Meet contractual and audit requirements (for example with NHS or public sector clients)  

2. Client or customer accounts and administration

We collect and use: 

  • Names and contact details 
  • Organisation and job role 
  • Purchase and service history 
  • Account / booking information 
  • Information used for security and access control 
  • Technical data (such as IP address, browser or operating system when you use our website or online platforms) 

We use this information to create and manage accounts, bookings and contracts; to keep accurate records; and to provide ongoing support.  

3. Information updates and marketing

We collect and use: 

  • Names and contact details 
  • Organisation and role 
  • Marketing preferences 
  • Service and engagement history 
  • Basic website / email interaction data (for example which updates are opened) 

We use this to send relevant updates about our services (such as new training dates, events or resources) and to avoid sending you information you have said you do not want. 

We do not sell your data to third parties.  

4. Legal, safeguarding and welfare obligations

We may collect and use: 

  • Identity and contact details 
  • Safeguarding concerns or incident details 
  • Information about risks to a person’s safety or wellbeing 
  • Health and safety information 
  • Limited criminal offence data where required by law (for example, if we are advised to make or respond to a safeguarding report) 

We use this information to: 

  • Comply with legal and regulatory obligations (for example safeguarding, health and safety, tax and accounting law) 
  • Protect someone’s vital interests where there is a serious risk of harm 
  • Keep appropriate records of safeguarding or incident reports  

5. Recruitment (staff, apprentices, freelancers)

We collect and use: 

  • Contact details 
  • CVs, application forms and interview notes 
  • Employment and education history 
  • Right to work information and ID documents 
  • Referee details and references 
  • Where relevant and lawful, Disclosure and Barring Service (DBS) or similar checks 
  • We may also collect limited health information where needed to make reasonable adjustments in the recruitment process. 

We use this information to assess suitability for roles, manage recruitment fairly, and comply with employment and right-to-work laws. 

 

Lawful bases and your data protection rights 

Under UK data protection law, we must have a lawful basis for using your personal information. 

For the purposes described above, we rely on: 

  • Contract – where we need to process your information to enter into or perform a contract with you (for example providing coaching or training you have booked). 
  • Legitimate interests – where we use your information in ways you would reasonably expect, which are necessary for our business and do not override your rights. 
  • Legal obligation – where we must use your information to comply with the law (for example tax, accounting, safeguarding or employment law). 
  • Vital interests – in rare, urgent situations where someone’s life or serious harm risk may be involved. 
  • Consent – mainly for marketing communications and for some uses of sensitive information. When we rely on consent, you can withdraw it at any time. 

Our use of legitimate interests 

We process certain personal information under the lawful basis of Legitimate Interests to deliver, manage and improve our training, consultation, coaching and related services. This includes: 

  • Communicating with clients and participants 
  • Arranging sessions, sending updates and sharing materials 
  • Tailoring support to individual and organisational needs 
  • Monitoring quality, accessibility and outcomes 
  • Planning capacity and service development 
  • Protecting the security and integrity of our systems and services 

We have assessed that this processing is proportionate, expected and does not override your rights. We only collect the minimum information needed, use it for clear purposes, keep it for limited periods and never sell it. 

You have the right to object to processing based on legitimate interests. We will consider any objection carefully and explain our decision. 

Your data protection rights 

You have the following rights: 

  • Right of access – to ask for copies of your personal information and related details. 
  • Right to rectification – to ask us to correct inaccurate or incomplete information. 
  • Right to erasure – to ask us to delete your information in certain circumstances. 
  • Right to restriction – to ask us to limit how we use your information. 
  • Right to object – to object to certain types of processing, including direct marketing and processing based on legitimate interests. 
  • Right to data portability – to ask us to transfer information you provided to another organisation or to you, in some circumstances. 
  • Right to withdraw consent – where we rely on consent, you can withdraw it at any time. 

To exercise any of these rights, contact us using the details at the top of this notice. We will respond without undue delay and within one month. 

 

Where we get personal information from 

We may obtain personal information from: 

  • You directly (for example when you book a session, complete a form or contact us) 
  • Your employer or commissioning organisation (for example when they book training for staff) 
  • Publicly available sources (for example professional profiles or websites, where relevant) 
  • Our service providers (for example payment processors, email and event platforms) 
  • Referees and previous employers (for recruitment) 

We do not buy large marketing lists or use covert data harvesting techniques. 

 

How long we keep information 

We keep personal information only for as long as necessary for the purposes described in this notice and to meet legal, accounting or reporting requirements. As a guide: 

  • Client and training records, contracts and invoices: up to 7 years after the end of the relationship 
  • Coaching and consultation notes: normally up to 7 years after the last session, unless legal or safeguarding reasons require a different period 
  • Safeguarding records: kept in line with legal and professional guidance (often longer than other records) 
  • Marketing contact details: until you unsubscribe or there has been no engagement for a reasonable period (for example 3 years) 
  • Recruitment (unsuccessful applicants): normally up to 12 months after the process ends 

If you want more detail about our retention schedule, please contact us. 

 

Who we share information with 

We only share your personal information where necessary and lawful. 

Data processors (organisations that process data on our behalf) 

We use carefully chosen service providers, for example: 

  • Cloud storage, email and productivity tools 
  • Accounting and payroll systems 
  • Online survey and event booking platforms 
  • IT support and security providers 

These processors can only use your data on our instructions, must keep it secure, and are not allowed to use it for their own purposes. 

Other organisations we may share information with 

Where relevant and lawful, we may share information with: 

  • Professional advisers (such as lawyers, accountants or insurers) 
  • Debt recovery agencies and courts (for unpaid invoices or legal claims) 
  • Regulatory or safeguarding bodies and emergency services, where required 
  • Organisations we are legally obliged to share information with (for example HMRC) 
  • Your employer or commissioning organisation, where they have arranged services for you (for example confirmation of attendance or completion) 

We will not share your information for unrelated marketing purposes without your consent. 

We do not routinely operate CCTV, call recording systems or vehicle tracking. If this ever changes, we will update this notice. 

We do not act as a joint controller with any other organisation for the activities described in this notice. 

How to complain 

If you have any concerns about how we use your personal data, please contact us first using the details at the top of this notice. We will do our best to resolve your concerns. 

If you remain unhappy, you can also complain to the Information Commissioner’s Office (ICO): 

Address
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF 

Helpline: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint