Data Protection & Privacy Notice

1. Introduction

This privacy notice explains how your personal data is collected, used, stored, and protected as part of coaching services.

This coaching practice operates in accordance with UK GDPR, The Data Protection Act (2018) and ethical principles set out by the International Coaching Federation (ICF).

Every reasonable effort is made to ensure your data is handled securely, ethically, and transparently.

2. Data Controller

Freya Freely Coaching is the data controller responsible for your personal data.

Contact details: freyafreelycoaching@gmail.com

3. What Personal Data Is Collected

The types of personal data collected may include:

  • Name and contact details
  • Coaching session notes and reflections
  • Payment and invoicing information
  • Communications (emails, messages, recordings where applicable)

Where relevant, this may include special category data (e.g. health or wellbeing information).

4. Lawful Basis for Processing

Your data is processed under:

  • Contract – to deliver coaching services
  • Legitimate interest – to manage and improve coaching practice
  • Legal obligation – for financial and regulatory compliance

5. How Your Data Is Used

Your data may be used to:

  • Deliver coaching sessions
  • Maintain accurate coaching records
  • Support continuity and quality of coaching
  • Communicate and manage scheduling
  • Meet legal, financial, and insurance obligations
  • Support supervision and reflective practice (in anonymised form where possible)

6. Use of Third-Party Services and AI Tools

Coaching services may involve third-party platforms, including but not limited to:

  • Video conferencing tools (e.g. Zoom and AI-enabled features such as Zoom AI Companion)
  • Cloud storage providers
  • Email and scheduling systems

Where AI tools are used:

  • They may process session audio, transcripts, or summaries
  • They are used to support coaching delivery (e.g. note-taking)
  • No solely automated decisions with legal or significant effects are made

Reasonable steps are taken to ensure providers comply with data protection standards, though absolute security cannot be guaranteed. You may request that AI tools are not used.

7. Data Storage (Cloud and Local)

Your data may be stored:

  • On secure cloud-based platforms, and/or
  • On local encrypted devices

Security measures include:

  • Password protection and access controls
  • Encryption where appropriate
  • Secure storage and deletion practices

Every reasonable attempt is made to safeguard confidentiality and data integrity.

8. Data Retention

Data is retained only as long as necessary, in line with legal and professional requirements:

  • Coaching records and notes:  up to 6 years after the end of the coaching relationship
  • Financial records: 6 years (HMRC requirements)
  • Enquiries (non-clients): up to 24 months
  • Session recordings: typically 30–90 days, unless otherwise agreed

Retention may be extended where required for:

  • Legal claims
  • Insurance purposes
  • Regulatory compliance

Data is securely deleted or anonymised when no longer required.

9. Your Rights

Under UK GDPR, you have the right to:

  • Access your data
  • Correct inaccurate data
  • Request deletion
  • Restrict or object to processing
  • Data portability (where applicable)

Requests will be responded to within one month.

10. Data Sharing

Your data will not be shared with third parties except:

  • Where required by law
  • Where necessary for service provision (e.g. IT providers)
  • With your explicit consent

11. Complaints

If you have concerns, you may contact:

The Information Commissioner’s Office

The ICO’s address:            
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

You are encouraged to raise concerns directly first: freyafreelycoaching@gmail.com. 

12. Updates to This Notice

This notice may be updated periodically. The latest version will be available on request or via the website.

13. Acknowledgement

By entering into coaching with Freya Freely Coaching, you confirm that:

  • You have read and understood this notice
  • You understand how your data will be used