Privacy Notice and GDPR Policy
Last updated: February 2026
Welcome to Wagtail Coaching. Your privacy is important to us. This Privacy Notice and GDPR Policy explains how we collect, use, and protect your personal information when you visit our website or use our services.
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1. Who We Are
Wagtail Coaching (“we”, “us”, “our”) is a professional coaching organisation offering coaching services to individuals and organisations.
Our website address is: www.wagtailcoaching.com
We are the Data Controller for the personal data we process.
Contact details:
Name: Simon Harris
Business Address: Available on request
Email: simon@wagtailcoaching.com
If you have questions about this policy or how your data is handled, contact us using the details above.
We are registered with the Information Commissioner’s Office (ICO).
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2. What Personal Data Information We Collect
2.1 Identity and Contact Information
We may collect and process the following categories of personal data:
• Contact details (e.g. name, email address, phone number, address if required for invoicing)
• Information you provide through forms, emails, or consultations
• Usage data (e.g. IP address, browser type, pages visited)
• Cookies and similar tracking technologies to improve our website
2.2 Coaching Relationship Information
Session dates and scheduling details
Coaching goals and agreed actions
Session notes (written by the coach)
Coaching summaries or progress notes
Communication records (email, WhatsApp)
2.3 Technical / Online Data
IP address (if you use a website contact form)
Website usage data (if analytics tools are enabled)
2.4 Payment Information
Invoices issued
Payment history
We do not intentionally collect special category data (such as health data) unless it is shared voluntarily and is relevant to the coaching relationship.
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3. Special Category Data (Sensitive Data)
During coaching, clients may share sensitive personal data such as:
Mental health or wellbeing details
Medical diagnoses (e.g. ADHD, autism)
Relationship information
Religious or cultural beliefs
Workplace grievances or disciplinary matters
We treat this as special category data under UK GDPR and apply increased confidentiality and security measures.
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4. How We Collect Your Data
We collect personal data from:
You directly (via enquiry forms, email, phone, Zoom calls, or onboarding forms)
Referrals (with your consent)
Your organisation (if they sponsor your coaching)
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5. Why We Use Your Data (Purposes)
We process your personal data for the following purposes:
To provide coaching services
To communicate with you about sessions and progress
To keep coaching records and track development
To send invoices and manage payments
To meet legal and regulatory requirements
To improve our service quality and client outcomes
To maintain professional records in case of dispute or complaint
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6. Lawful Basis for Processing (UK GDPR)
We rely on the following lawful bases:
6.1 Contract
Where processing is necessary to deliver coaching services agreed with you.
6.2 Legitimate Interests
Where we have a legitimate reason to process data, such as:
Keeping session notes to support coaching quality
Managing scheduling and administration
Maintaining records to protect ourselves legally in case of complaint or dispute
We ensure your rights and freedoms are not overridden.
6.3 Legal Obligation
Where we must comply with legal requirements, such as HMRC rules relating to invoices and tax records.
6.4 Consent
We rely on consent where required, including:
Recording sessions
Using AI tools to generate summaries/transcripts (where applicable)
Processing special category data where necessary and appropriate
You can withdraw consent at any time.
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7. Coaching Notes and Records
We may keep coaching notes which can include:
Themes discussed
Progress updates
Agreed actions
Reflections to support future sessions
We aim to keep notes professional, relevant and proportionate.
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8. Zoom / Online Coaching and Recordings
Sessions may take place via Zoom, Microsoft Teams, Google Meet or similar platforms.
8.1 Session Recording
We do not routinely record coaching sessions unless agreed in advance.
If a session is recorded:
you will be told clearly before recording begins
the purpose of the recording will be explained
you may refuse recording without any impact on your coaching service
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9. AI Tools and Automated Processing
We may use AI tools to support administrative efficiency, including generating summaries of coaching sessions.
This may include:
AI-generated meeting summaries
AI-generated transcripts
AI-supported action point lists
9.1 What AI is Used For
AI tools may be used for:
summarising session discussions into notes
identifying key action points
producing structured follow-up emails
saving time and improving accuracy of session administration
9.2 What AI is NOT Used For
AI is not used to:
make decisions about you automatically
provide psychological diagnosis
replace professional judgement
make employment decisions or assessments
All coaching decisions remain human-led.
9.3 What Data May Be Shared With AI Tools
If enabled, AI tools may process:
your spoken words in session (via transcript)
session content and context
action points and commitments
9.4 Lawful Basis for AI Use
We process data using AI under:
Legitimate Interests (efficient admin and accurate session summaries), and/or
Consent (particularly where special category data may be involved or where tools require recording/transcription)
Clients can request a non-AI alternative at any time.
9.5 Client Choice and Opt-Out
You may opt out of AI processing at any time.
If you opt out:
we will take manual notes instead
we will not upload session content to AI tools
9.6 Confidentiality and Data Minimisation
We aim to minimise what is shared with AI tools by:
using summaries rather than full transcripts where possible
removing unnecessary identifying information where practical
storing only essential outputs
9.7 Data Location and International Transfers
Some AI providers may process data outside the UK.
Where international transfers occur, we take reasonable steps to ensure appropriate safeguards are in place, such as:
UK GDPR adequacy regulations
standard contractual clauses
vendor security assurances
9.8 Human Review
AI outputs are reviewed by the coach.
They may contain errors and are not treated as perfect records.
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10. Who We Share Your Data With
We may share personal data with:
10.1 Service Providers (Data Processors)
email providers
cloud storage providers
accounting software providers
video conferencing providers (Zoom/Teams etc.)
scheduling tools (Calendly etc.)
AI summarisation tools (where used)
These suppliers only process data under instructions and for the purpose of delivering services.
10.2 Professional and Legal Disclosure
We may share data if required:
by law
for legal claims
to prevent fraud
to protect safety
10.3 Employers (If Sponsored Coaching)
If your coaching is funded by your employer:
we do not share session content without your explicit consent
we may share attendance confirmations or high-level themes only if agreed
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11. Data Security
We take reasonable steps to protect personal data including:
password-protected devices
encrypted cloud services where possible
secure storage of notes
limiting access to client records
regular review of tools and security settings
Despite security measures, no system is completely risk-free.
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12. Data Retention Policy (Retention Schedule)
We retain personal data only for as long as necessary for the purposes it was collected.
Below is our standard retention schedule:
12.1 Data Retention Schedule
We only keep personal information for as long as necessary to provide our services, meet legal obligations, and protect both our clients and our business.
If you contact us with an enquiry but do not become a client, we will retain your enquiry records, such as emails or contact form submissions, for up to 12 months. This allows us to respond to follow-up queries and manage our business effectively.
If you become a coaching client, we will retain onboarding records, including intake forms and coaching agreements, for 6 years after coaching ends. This is for legal and contractual purposes.
Coaching notes, including session notes and agreed action points, are kept for up to 2 years after your final session. This helps ensure continuity of service and provides appropriate safeguarding and dispute protection. Where AI tools are used to generate coaching summaries, these are also retained for up to 2 years, or deleted sooner if no longer needed.
If coaching sessions are recorded (for example, via Zoom), recordings are normally deleted within 30 days unless we agree otherwise with you. Where transcripts are created, full transcripts are retained for up to 90 days and then securely deleted, in order to minimise the retention of sensitive personal information.
Administrative communications, such as emails or messages relating to scheduling or service delivery, are kept for up to 2 years after our last contact to support continuity and good service.
Financial records, including invoices and payment records, are retained for 6 years from the end of the relevant financial year. This is required by UK tax law and HMRC regulations.
If you subscribe to our newsletter or marketing communications, we will retain your details until you unsubscribe or after 24 months of inactivity, whichever occurs first.
If a formal complaint is made, records relating to the complaint will be retained for 6 years after the complaint is resolved. This is to meet legal and professional obligations.
We regularly review our data and securely delete information that is no longer required.
Notes on Retention
You can request deletion sooner (see your rights below).
If we must retain certain records for legal reasons, we may keep minimal data for that purpose only.
Where possible, we may anonymise records instead of deleting them.
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13. Your Rights Under UK GDPR
You have the right to:
Access your data (Subject Access Request)
Correct inaccurate data
Request deletion (“right to be forgotten”)
Restrict processing
Object to processing
Data portability
Withdraw consent (where consent is the lawful basis)
To exercise your rights, email: info@wagtailcoaching.com
We will respond within one month unless the request is complex.
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14. Complaints
If you are unhappy with how your data is handled, you can complain to us first.
You also have the right to complain to the UK ICO:
Information Commissioner’s Office
Website: ico.org.uk
Telephone: 0303 123 1113
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15. Cookies and Website Analytics (if applicable)
If we use cookies or analytics tools, these may collect limited technical information.
A cookie banner may appear when visiting our website.
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16. Children’s Data
We do not knowingly provide coaching services to children under 18 without parental consent and appropriate safeguarding arrangements.
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17. Changes to This Policy
We may update this policy from time to time.
The latest version will always be available on request or published on our website.
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18. Quick Summary
We keep minimal coaching notes to support your progress.
We may use secure AI tools to generate session summaries, but you can opt out at any time.
We never sell your data.
We store your data securely and delete it according to a retention schedule.