Privacy Notice
1. Introduction
Michael Storey (“the Coach”) is committed to protecting the privacy and security of personal data. This Privacy Notice explains how the Coach collects, uses, stores, and protects personal information when providing coaching or mentoring services.
This notice applies to all clients and prospective clients of the Coach’s coaching and mentoring services.
2. Data controller details
Michael Storey (“the Coach”) is the data controller. Please use the form on the Contact page to get in touch.
3. Personal data collected
The Coach collects and processes the following categories of personal data:
Contact information:
● Name
● Email address
● Phone number
Financial information:
● Payment and invoicing details (the Coach does not store full card details—these are processed securely by the payment processor)
Session information:
● Records of session dates, times, and duration
● Brief, pseudonymised handwritten notes (see Section 6 below)
Communications:
● Email, text message or phone correspondence
● Any information you choose to share during coaching or mentoring sessions
4. How personal data is collected
The Coach collects personal data:
● Directly from clients when they enquire about or book services
● Through email, phone, or video call communications
● During coaching or mentoring sessions
● Through the payment processor when clients make payments
● From referral partners, where an individual has agreed to an introduction or the sharing of their contact details
5. Lawful basis for processing personal data
The Coach processes personal data on the following lawful bases under UK GDPR:
a) Contract performance: Contact details, payment information and session scheduling information are necessary to deliver the coaching or mentoring services contracted with the Coach.
b) Legitimate interests: The Coach has a legitimate interest in:
● Keeping session notes to ensure continuity and quality of service
● Maintaining records for International Coaching Federation (ICF) credentialing purposes (professional accreditation)
● Keeping financial records for accounting and tax compliance
● Discussing coaching practice in professional supervision (see Section 8)
● Recording and administering referral introductions and any related referral fee
c) Legal obligation: The Coach is required by law to retain certain financial records for HMRC and tax purposes.
6. Session notes
Any notes taken by the Coach are in the form of brief handwritten records using initials only (no full names or other identifying details) as memory aids for session continuity. These notes are:
● Minimal and pseudonymised
● Intended primarily for the Coach’s own reference
● Informal handwritten records that may be of limited utility to clients
Clients have the right to request access to any notes the Coach holds about them (see Section 12 below).
7. ICF credentialing records
As a member of the International Coaching Federation (ICF), the Coach maintains limited records of:
● Client name
● Contact details
● Coaching session duration
These records may be reviewed by the ICF as part of spot-check or audit processes to verify that required coaching hours were completed through legitimate paid coaching engagements.
This processing is based on the Coach’s legitimate interest in maintaining professional accreditation. Clients have the right to object to this processing (see Section 12).
8. Coaching supervision
As part of professional development and in accordance with ICF standards, the Coach participates in regular coaching supervision. During supervision sessions, the Coach may discuss coaching cases, sessions, and client situations with a qualified supervisor.
Important: All such discussions are conducted on an anonymised and non-identifying basis. The Coach does not share client names or other identifying details with the supervisor. The supervisor is bound by their own professional confidentiality obligations.
The purpose of supervision is to ensure the quality and ethical standards of the Coach’s practice and to support continuing professional development.
9. Data sharing
The Coach does not sell, rent, or trade personal data to third parties.
Limited personal data may be shared with:
Payment processors: Only the transaction data necessary to process payments
The International Coaching Federation (ICF): Limited data (name, contact details, session duration) for credentialing verification purposes only
The Coach’s professional supervisor: Anonymised and non-identifying information only (no names or identifying details)
Legal authorities: Where required by law (e.g., court order, regulatory requirement)
Referral partners: Limited contact details and information about the introduction, where an individual has agreed to the sharing of their details or where the sharing is otherwise permitted by law.
10. Referral introductions
The Coach may receive introductions from, or make introductions to, other professionals or organisations where the individual has indicated that they may be interested in the receiving party’s services.
Before sharing an individual’s contact details with a referral partner, the Coach will obtain the individual’s permission to do so where required. Where the Coach receives an introduction from a referral partner, the Coach expects that partner to have obtained the individual’s permission to share their contact details where required. An individual may choose whether to contact, accept services from, or enter into an agreement with the receiving party.
Where the Coach receives an introduction, the Coach may process the individual’s name, contact details and limited information about the introduction in order to contact the individual, discuss or provide coaching or mentoring services, administer any referral arrangement, and meet legal, accounting and professional obligations.
Where the Coach makes an introduction, the Coach may record limited information about the introduction, including the date, the receiving party and whether any referral fee is due. The Coach will not share information from coaching or mentoring sessions with a referral partner unless the individual has given express permission or disclosure is otherwise required by law.
The Coach and each referral partner act as separate data controllers for the personal data each receives and processes. Each is responsible for its own compliance with applicable data protection law and for providing its own privacy information.
Where a referral fee or other benefit is paid, received or may become payable in connection with an introduction, the Coach will disclose this to the relevant client as appropriate and in accordance with the International Coaching Federation (ICF) Code of Ethics.
11. International transfers
The Coach is based in the United Kingdom. Personal data may be stored or processed in the United Kingdom and, where the Coach uses service providers based outside the United Kingdom, in other countries.
Where personal data is transferred outside the United Kingdom, the Coach will use appropriate safeguards required by UK data protection law, such as an adequacy decision or the UK International Data Transfer Agreement or Addendum, where applicable.
12. Client rights under data protection law
Under UK data protection law, the Client has the following rights:
a) Right of access: the Client can request a copy of the personal data the Coach holds about them.
b) Right to rectification: the Client can ask the Coach to correct any inaccurate personal data.
c) Right to erasure: the Client can ask the Coach to delete their personal data in certain circumstances (subject to legal retention requirements, such as HMRC’s 6-year requirement for financial records).
d) Right to restrict processing: the Client can ask the Coach to stop processing their personal data in certain circumstances.
e) Right to data portability: the Client can request their personal data in a structured, commonly used format.
f) Right to object: the Client can object to processing based on legitimate interests, including ICF credentialing records.
g) Right to withdraw consent: Where processing is based on consent, the Client can withdraw it at any time (note: most processing is based on contract performance or legitimate interests, not consent).
How to exercise these rights: The Client should contact the Coach in writing (email or post) using the contact details in Section 2. The Coach will respond within one month of receiving the request.
13. Data retention periods
The Coach retains personal data for the following periods:
Session notes: Securely disposed of within 12 months of the end of the coaching relationship, unless you request earlier disposal.
Financial records: Retained for 6 years from the end of the financial year in which the transaction occurred (HMRC requirement).
Contact details: Deleted within 12 months of the end of the coaching relationship, unless required for ongoing financial record-keeping.
ICF credentialing records: Retained for the duration of the Coach’s ICF membership or as long as required for credentialing purposes, whichever is longer.
Referral records: Retained for 6 years from the end of the financial year in which the relevant referral fee became payable or, where no fee becomes payable, for 12 months from the date of the introduction.
14. Data security
The Coach takes the security of personal data seriously and uses appropriate technical and organisational measures to protect it, including:
● Password-protected devices
● Secure email communications.
● Secure disposal of handwritten notes (cross-cut shredding).
● Regular deletion of data in accordance with the retention periods in Section 13.
● Limiting access to personal data to only what is necessary.
15. Third-party platforms
If sessions are conducted using third-party video conferencing platforms (e.g., Zoom, Google Meet, Microsoft Teams), such platforms have their own privacy policies and data processing practices. The Coach uses reasonable efforts to select secure platforms and configure appropriate privacy settings.
16. Confidentiality
All information shared during coaching and mentoring sessions is confidential, subject to the following exceptions:
Confidentiality does not apply where:
● Disclosure is required by law (e.g., court order, regulatory requirement).
● The Coach reasonably believes there is a risk of serious harm to the client or others.
● The client provides express permission for information to be shared.
17. Changes to this Privacy Notice
The Coach may update this Privacy Notice from time to time to reflect changes in practices or legal requirements. Clients will be notified of any significant changes by email or through the website.
Current version: 20260909
18. Right to complain
If there are concerns about how personal data is processed, clients have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO):
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk
The Coach would appreciate the opportunity to address any concerns directly, so please contact the Coach first if there are any issues.
19. Contact
For any questions about this Privacy Notice or how personal data is handled, please contact the Coach in writing, using the contact details in Section 2. The Coach will respond within one month of receiving the request.
This Privacy Notice was last updated on 09 September 2026 and applies to all coaching and mentoring services provided by Michael Storey