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”). 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
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)
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 11 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 11).
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)
10. International transfers
Personal data is stored and processed within the United Kingdom.
If the Coach uses any service providers that process data outside the UK (e.g., cloud storage or video conferencing platforms), appropriate safeguards such as Standard Contractual Clauses or adequacy decisions will be in place to protect the data.
11. 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.
12. 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.
13. 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 12.
● Limiting access to personal data to only what is necessary.
14. 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.
15. 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.
16. 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: 20260316
17. 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.
18. 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 16th March 2026 and applies to all coaching and mentoring services provided by Michael Storey.