Since the client-coach relationship is deeply personal my client has a right to expect that what she or he reveals will be kept private.
As a coach, if I wish to share client information with others (e.g. my supervisor and/or other helping professionals) I am required, and committed, to get my client’s permission first.
As a coach I am ethically and legally required to discuss with my client the circumstances that might affect the confidential relationship.
Ethical limits to confidentiality – the obligation to warn and protect:
In cases of suspected incest, child abuse, and neglect, as a coach I have ethical and legal obligations to report the information to DOCS, or the appropriate authorities.
Clients who are suicidal or who pose a serious danger to others also require that I take action to ensure harm does not occur to them or others.
This duty of care normally over-rides the confidentiality requirement.
In addition, confidentiality cannot be guaranteed when my client is a minor, or in certain instances when coaching partners, or groups.
Part Two: The ICF Standards of Ethical Conduct
SECTION 1: PROFESSIONAL CONDUCT AT LARGE
As a coach:
11. I maintain, store and dispose of any records, including electronic files and communications, created during my coaching engagements in a manner that promotes confidentiality, security, and privacy, and complies with any applicable laws and agreements.
SECTION 4: CONFIDENTIALITY / PRIVACY
As a coach:
24. I maintain the strictest levels of confidentiality with all client and sponsor information unless required by law.
25. I have a clear agreement about how coaching information will be exchanged among coach, client, and sponsor.
26. I have a clear agreement when acting as a coach, coach mentor, coaching supervisor or trainer, with both client and sponsor, student, mentee, or supervisee about the conditions under which confidentiality may not be maintained (e.g. illegal activity, pursuant to valid court order or subpoena; imminent or likely risk of danger to self or to others; etc) and make sure both client and sponsor, student, mentee or supervisee voluntarily and knowingly agree in writing to that limit of confidentiality. Where I reasonably believe that because of one of the above circumstances is applicable, I may need to inform appropriate authorities.
27. I require all those who work with me in support of my clients to adhere to the ICF Code of Ethics, Number 26, Section 4: Confidentiality and Privacy Standards, and any other sections of the Code of Ethics that might be applicable.
The types of personal information I may collect about you include:
images of you;
your contact details, including email address, mailing address, street address and/or telephone number;
your marital status and/or anniversary;
your age and/or date of birth;
your demographic information, such as postcode;
your preferences and/or opinions;
information you provide to me through coaching documentation, customer surveys, comment forms or contact forms;
details of products and services I have provided to you and/or that you have enquired about, and my response to you;
your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
information about your access and use of my Site, including through the use of Internet cookies, your communications with my Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
additional personal information that you provide to me, directly or indirectly, through your use of my Site, associated applications, associated social media platforms and/or accounts from which you permit me to collect information; and
any other personal information requested by me and/or provided by you or a third party.
I may collect these types of personal information directly from you or from third parties.
Collection and use of personal information
I may collect, hold, use and disclose personal information for the following purposes:
to enable you to access and use my Site, associated applications and associated social media platforms;
to contact and communicate with you;
for internal record keeping and administrative purposes;
for analytics, market research and business development, including to operate and improve my Site, associated applications and associated social media platforms;
to run competitions and/or offer additional benefits to you;
for advertising and marketing, including to send you promotional information about my products and services and information about third parties that I consider may be of interest to you; and
to comply with my legal obligations and resolve any disputes that I may have.
Disclosure of personal information to third parties
I may disclose personal information to:
third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
my employees, contractors and/or related entities;
my existing or potential agents or business partners;
sponsors or promoters of any competition I run;
anyone to whom my business or assets (or any part of them) are, or may (in good faith) be, transferred;
credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services I have provided to you;
courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend my legal rights;
third parties, including agents or sub-contractors, who assist me in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia; and
third parties to collect and process data, such as [Google Analytics or other relevant businesses]. This may include parties that store data outside of Australia.
By providing me with personal information, you consent to the disclosure of your personal information to third parties who reside outside Australia and acknowledge that I am not required to ensure that those third parties comply with Australian privacy laws.
How I treat personal information that is also sensitive information
Sensitive information is a subset of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.
Sensitive information includes:
- an individual’s racial or ethnic origin,
- health information,
- political opinions,
- membership of a political association,
- professional or trade association or trade union,
- religious beliefs or affiliations,
- philosophical beliefs,
- sexual orientation or practices,
- criminal record,
- genetic information,
- biometric information that is to be used for certain purposes, and
- biometric templates.
Your rights and controlling your personal information
Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to me using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
Access: You may request details of the personal information that I hold about you. An administrative fee may be payable for the provision of such information. In certain circumstances, as set out in the Privacy Act 1988 (Cth), I may refuse to provide you with personal information that I hold about you.
Correction: If you believe that any information I hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact me using the details below. I will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Complaints: If you believe that I have breached the Australian Privacy Principles and wish to make a complaint, please contact me using the details below and provide me with full details of the alleged breach. I will promptly investigate your complaint and respond to you, in writing, setting out the outcome of my investigation and the steps I will take to deal with your complaint.
Unsubscribe: To unsubscribe from my e-mail database or opt-out of communications (including marketing communications), please contact me using the details below or opt-out using the opt-out facilities provided in the communication.
Storage and security
I am committed to ensuring that the personal information I collect is secure. In order to prevent unauthorised access or disclosure, I have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
Cookies and web beacons
I may use web beacons on my Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
Links to other websites
For any questions or notices, please contact me at:
Pablo Bensemann: Transpersonal Coach (ABN: 98 592 504 109)
Last update: 13 December 2018