Privacy Notice

This notice explains how I handle your personal information as your coach and/or mentor.  I am the data controller, which means I decide how and why your data is used. I comply with the GDPR and the Irish Data Protection Act 2018.

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1. What I collect

• Contact and booking details: name, email, phone number, and your employer if relevant.

• Session information: notes I make, goals, action plans, and anything you choose to share during coaching.

• Payment details: invoices and payment records (I do not store card numbers).

• Sensitive information: if you choose to share health-related information, I treat it as special category data (see section 3).

 

2. Why I use it and my legal basis

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Purpose: Delivering and administering our coaching, scheduling, communicating with you

Legal basis:  Performance of our contract

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Purpose: Invoicing and keeping accounting records

Legal basis: Contract and legal obligation (Revenue requirements)

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Purpose: Safeguarding or legal disclosures where required

Legal basis: Legal obligation / protecting vital interests

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Purpose: Recording sessions or noting health information you share

Legal basis: Your explicit consent

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I do not use your data for marketing unless you separately ask to receive it, and I never sell it.

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3. Sensitive information and recordings

I do not record sessions or keep notes of health-related information. If for any reason you would like to have a session recorded or notes of health-related information kept, I can do so with your explicit consent, given separately in an agreement. You can withdraw consent at any time by contacting me, and I will stop recording or delete the relevant material (unless I am legally required to keep it).

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4. Who I share it with

Sessions and records are confidential, in line with the EMCC and ICF Codes of Ethics. I share data only with:

• Service providers who help me run my practice, who process data on my behalf: e.g. Zoom, GoogleMeet, Microsoft 365, Calendly calendar tool.

• Sponsors in B2B Contracts, where my coaching/mentoring is sponsored by an employer, I share only attendance / progress themes with the Sponsor. The content of sessions stays confidential to the Client(s) unless they agree otherwise.

• My professional supervisor, in anonymised form where possible.

• Authorities or others where I am legally required to, or where there is a serious safeguarding concern.

• Anyone else only with your explicit consent.

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Some providers may store data outside the EEA (for example in the US). Where this happens, it is protected by safeguards such as the EU-US Data Privacy Framework or Standard Contractual Clauses.

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5. How long I keep it

• Session notes and coaching records: 12 months after our work ends, then securely deleted.

• Session recordings (if any): deleted within 30 days or immediately on your request.

• Invoices and payment records: 6 years, as required for Revenue purposes.

• Contact details: until you ask me to delete them or 2 years after our last contact.