Data Retention and Deletion Policy

Last updated: July 2025

1. Purpose of this policy
I take the privacy of my clients seriously. I collect and retain only the personal information that I reasonably need to provide my coaching services, run my business and meet my legal obligations.

I do not keep personal information indefinitely simply because it might be useful in the future.

This policy explains what information I keep, how long I keep it and what happens when my work with a client ends.

2. My general retention principle
Personal information will be retained only for as long as there is a clear reason for keeping it.

This may be because:

• it is needed while I am working with a client;

• the client has specifically asked me to retain their coaching records for a limited further period;

• it is required for accounting, taxation or other legal purposes;

• it is needed to deal with an outstanding payment, refund, complaint or dispute; or

• there is another legitimate and lawful reason for retaining it.

When there is no longer a reason to retain personal information, I will securely delete or anonymise it.

3. Information held while I am working with a client
During our work together, I may hold information including:

• your name;

• your email address;

• your telephone number;

• appointment and booking information;

• correspondence between us;

• coaching and session notes;

• journal entries or other information you choose to provide;

• information relevant to the issues we are working on together; and

• limited payment and administrative information.

Because of the nature of coaching, some of the information you choose to share may be personal or sensitive.

I do not normally collect or require your home or postal address as part of my coaching records.

A third-party payment provider may independently request information such as a billing address where this is required to process a payment. Information collected directly by that provider is subject to its own privacy and retention arrangements.

4. What happens when our coaching work ends
I deliberately operate a short retention period for coaching records.

Four weeks after our work together has ended, I will contact you to ask what you would like me to do with your identifiable coaching records.

You will be given two choices.

Option 1 – Retain my coaching records
You may ask me to retain your coaching records so that, should you decide to work with me again, we can more easily continue from where we left off.

If you choose this option, I will retain your coaching records for a further 12 months.

You may ask me to delete them at any time during that period.

At the end of the 12-month period, I will not simply retain the information indefinitely. I will either delete it or contact you again if there is a genuine reason to consider retaining it for a further limited period.

Option 2 – Delete my coaching records
You may ask me to delete your identifiable coaching records.

If I do not receive a response from you within seven days of my retention email, I will treat this as your preference for deletion and will proceed accordingly.

In other words, you do not have to ask me to delete your records. If you do nothing, deletion is the default.

5. What I delete
When your coaching records are deleted, I will delete the identifiable coaching information under my control that I no longer have a lawful reason to retain.

This will normally include:

• session notes;

• coaching notes;

• journal entries you have provided;

• documents or personal material supplied for coaching purposes;

• your name from my coaching records;

• your email address from my coaching records;

• your telephone number from my coaching records; and

• other identifiable information held specifically for the purposes of our coaching work.

The objective is to remove your identifiable coaching file rather than retaining it unnecessarily.

This does not necessarily mean that every reference to a financial transaction involving you can also be deleted. Financial and accounting records are dealt with separately below.

6. Payments by debit card, credit card, Stripe or Klarna
Payments for my services may be processed through third-party payment providers such as Stripe or Klarna.

Where you pay by debit card, credit card or another payment method provided through one of these services, your payment information is processed by the relevant payment provider.

I do not normally receive or store your complete debit or credit card number, card security code or other complete card credentials.

The payment provider may collect information directly from you that it requires to process the transaction, prevent fraud, verify identity, provide a credit or payment facility or comply with its own legal obligations.

That information is handled by the payment provider in accordance with its own privacy and retention policies.

I may receive and retain limited information about a transaction, such as:

• your name;

• the amount paid;

• the date of payment;

• a transaction or payment reference;

• the payment method or provider used;

• confirmation of whether payment was successful;

• invoices or receipts; and

• information required to deal with a refund, payment query or dispute.

This financial information is separate from your confidential coaching notes and journal material.

7. Financial, accounting and tax records
Deleting your coaching records does not necessarily mean that I can delete every financial record relating to payments you have made.

I am required to retain appropriate business and accounting records for the period required by UK tax and accounting law.

This may include invoices, payment records, transaction references and other information required to demonstrate money received by my business.

Financial records will be retained only for the period required for accounting, taxation, regulatory or other legitimate legal purposes.

They will not be used as a reason to retain your coaching notes, journal entries or other sensitive coaching information.

Where your name or other limited identifying information must remain on an invoice, transaction record or accounting entry, that information may therefore remain after your coaching file has been deleted.

8. Payment disputes, refunds and chargebacks
Where there is an outstanding payment, refund request, chargeback, complaint or other dispute, I may retain information that is reasonably necessary to resolve the matter.

I will not retain unrelated coaching information simply because a financial dispute exists.

Once the matter has been resolved, information will either be deleted or retained only where there remains a legal, accounting or other legitimate reason for keeping it.

9. People who make an enquiry but do not become clients
If you contact me about coaching but do not subsequently become a client, I will not keep your information indefinitely.

Enquiry information will normally be deleted when it is clear that the enquiry is no longer active.

As a general rule, inactive enquiry information will be deleted within three months of our last meaningful contact, unless there is a legitimate reason for retaining it for longer.

10. Emails and correspondence
Emails and other communications may contain personal information.

Where correspondence forms part of the substantive coaching relationship, it will be treated in accordance with the retention arrangements described in this policy.

Administrative or financial correspondence may need to be retained for longer where it relates to accounting, payments, complaints, legal matters or another continuing obligation.

I periodically review correspondence and delete information that I no longer need.

11. Information held by third-party service providers
I use third-party services where necessary to operate my business. These may include services for:

• email;

• video meetings;

• appointment scheduling;

• electronic storage;

• website hosting;

• accounting;

• payments; and

• other business administration.

Where I control information stored within these services, I will delete information in accordance with this policy where the service allows me to do so.

Some providers maintain secure backup systems or retain limited information for their own legal, security, fraud-prevention or regulatory purposes.

Deletion from my active systems may therefore not always result in the immediate physical removal of every residual backup copy held within a third-party provider's infrastructure.

Any such backup copies remain subject to the provider's security and deletion procedures and are not retained by me for normal use.

12. Requests for earlier deletion
You do not have to wait until our coaching relationship has ended to ask me about the information I hold about you.

You may ask me to delete personal information at any time.

Where I have no continuing lawful reason or legal obligation to retain the information, I will delete it.

There may be circumstances in which I am legally entitled or required to retain limited information despite a deletion request. If this applies, I will explain what needs to be retained and why.

13. Legal claims, complaints and exceptional circumstances
In exceptional circumstances, it may be necessary to retain particular information for longer than the normal periods set out in this policy.

Examples include:

• an actual or reasonably anticipated legal claim;

• a formal complaint;

• a regulatory matter;

• fraud or suspected fraud;

• a payment dispute;

• a legal requirement; or

• an investigation by an appropriate authority.

In these circumstances, I will retain only the information reasonably necessary for that purpose and will review it when the reason for retaining it ends.

14. Secure deletion
When information is due for deletion, I will take reasonable steps to remove it securely from the systems and records under my control.

Where appropriate, information may instead be anonymised so that it can no longer be linked to an identifiable individual.

I do not sell deleted, anonymised or retained client information.

15. Regular review
I periodically review the personal information I hold and the reasons for retaining it.

Information that is no longer necessary will be deleted or anonymised unless there is a legal or legitimate reason for continuing to retain it.

I will also review this policy if my working practices, technology, payment providers or legal obligations change.

16. Questions about your information
If you would like to know what information I hold about you, request deletion, correct inaccurate information or ask a question about this policy, please contact me using the contact details provided on this website.