Privacy policy
Last updated: [date]
The short version
- I only collect what I need to reply to you, arrange coaching and run my business.
- Anything you share in coaching is treated as confidential.
- I never sell your information.
- This website doesn't use tracking or advertising cookies.
- You can ask to see, correct or delete your information at any time.
On this page
Who I am
Shift Coaching is run by Emma Payne [as a sole trader, OR through Company Name Ltd, company number 00000000]. I'm responsible for your personal information, which makes me the "data controller" under UK data protection law.
- Address: [business or correspondence address]
- Email: [email protected]
- ICO registration number: [ICO registration number]
What I collect
When you contact me or book a free clarity call
- Your name, email address and, if you give it, your phone number
- The dates and times you suggest for your call
- Whether the call is for you or your workplace
- Anything you choose to write in your message
- Whether you've agreed to receive occasional emails from me
When you message me on WhatsApp or by email
Your name, phone number or email address, and whatever you choose to tell me.
If you become a client
- Your answers to any intake or team audit questionnaire
- Notes I make during or after our sessions
- Plans, strategies and resources we create together
- Billing details, such as your address or your employer's invoicing details
I don't record sessions unless we've both agreed to it first.
Health and sensitive information
Coaching often involves talking about ADHD, neurodivergence, mental health or other health matters. The law treats this as "special category" information and gives it extra protection.
I only collect and use it with your explicit consent, which I'll ask for before we start working together. You can withdraw that consent at any time, although it may mean I can't continue coaching you.
Confidentiality and its limits. What you share in coaching stays between us. The only exception is if I believe you or someone else is at serious risk of harm. Then I may need to share information with the emergency services or another appropriate organisation. Where it's safe and possible, I'll talk to you about it first.
How I use it, and why
The law requires me to have a "lawful basis" for each way I use your information.
| What I do | Lawful basis |
|---|---|
| Reply to your enquiry and arrange your free clarity call | Legitimate interests (responding to people who contact me), or steps before entering a contract |
| Deliver coaching sessions and programmes | Contract |
| Use health or neurodivergence information in coaching | Explicit consent |
| Send invoices and keep financial records | Contract and legal obligation |
| Send occasional tips and updates by email | Consent, which you can withdraw at any time using the unsubscribe link |
| Share information if someone is at serious risk | Vital interests |
I don't make any decisions about you using automated systems or profiling.
If your employer is paying
If your workplace funds your coaching, I'll share what's needed to arrange and invoice it, such as your name, the programme and the dates of your sessions.
I won't share what you tell me in sessions, or your questionnaire answers, without your permission. [Emma to confirm: does she share any progress updates with employers, and if so, what and with whose agreement?]
Information stored outside the UK
Some of the services I use, including GoHighLevel, Google and WhatsApp, store information on servers outside the UK, mainly in the United States. When that happens, the transfer is protected by safeguards recognised under UK law, such as the UK-US data bridge or approved contract terms.
How long I keep it
- Enquiries that don't lead to coaching: [12 months] after we last spoke
- Client records and session notes: [6 years] after our last session
- Invoices and financial records: 6 years, as required by HMRC
- Email list: until you unsubscribe
After that, I delete it securely.
Your rights
Under UK data protection law, you have the right to:
- Ask for a copy of the information I hold about you
- Ask me to correct anything that's wrong or incomplete
- Ask me to delete your information
- Ask me to limit how I use it
- Object to me using it
- Ask me to pass it to you or another organisation in a usable format
- Withdraw your consent at any time, where I'm relying on consent
To use any of these rights, email [email protected]. There's no charge, and I'll reply within one month. Some rights have limits. For example, I have to keep financial records for HMRC.
Keeping it safe
I keep your information secure using password-protected accounts, two-factor authentication where available and devices that are locked when not in use. [Emma to confirm, and add anything else, such as where paper notes are stored.] If there's ever a data breach that puts you at risk, I'll let you know and report it to the ICO where the law requires it.
Contact and complaints
If you have a question or a concern about how I handle your information, please email [email protected] and I'll do my best to put it right.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator, at ico.org.uk or on 0303 123 1113.
I may update this policy from time to time. The date at the top shows when it last changed.