Anchors Coaching Limited is committed to protecting your privacy and complies with the principles of the relevant data protection regulations.

This privacy policy explains how Anchors Coaching Limited protects and makes use of any information you share with the company. If you are asked to provide information to the company, it will only be used in the ways described in this policy.

Anchors Coaching Limited gathers and uses certain information about clients where it is in the interest of the professional coaching practice provided. The company acts with integrity and is aligned with the guidance of the ICF, EMCC and AC.

Anchors Coaching – Privacy Policy

Last updated: 1 September 2026

1. Who we are

Anchors Coaching Limited ("we", "us", "our") is a coaching business.

Kate Clark, as Director, is responsible for the business's data protection arrangements and is the data controller for the personal data we process.

This policy is written in line with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Data (Use and Access) Act 2025.

Contact details:

Business: Anchors Coaching Limited

Contact: Kate Clark

Email: kate@anchorscoaching.co.uk

Phone: 0772 6466017

Address: Available on request

If you have any questions about this policy or how your personal data is handled, please contact me using the details above.

2. What personal data we collect

I collect the minimum amount of personal data needed to run the business and provide my services. I do not collect or store bank or payment card details.

Depending on how you interact with me, I may collect:

• Name and contact details, such as your email address and mobile number.

• Appointment and booking information, including details needed to arrange and deliver a coaching session.

• Information needed for invoicing and business records.

• Home or delivery address, where you ask me to send you a physical resource.

• Newsletter subscription information, including your email address and subscription preferences.

• Information you choose to share during coaching or other conversations.

Coaching conversations

Coaching is a confidential space and you may choose to share personal information with me as part of our work together.

I do not routinely create or retain electronic notes containing sensitive or special-category information arising from coaching conversations.

Where I make brief administrative notes, these are limited to information reasonably necessary to manage our coaching relationship and are stored securely.

With your explicit permission, I may use Fathom to record and transcribe a coaching conversation. I will always ask for your permission before using Fathom. You are free to decline, and this will not affect your coaching.

When Fathom is used, the recording and transcript are processed by Fathom on my behalf. Fathom states that its data is stored in the United States and that it offers a data processing agreement for UK customers. I will only use Fathom where you have given permission and will use appropriate settings and safeguards to protect the information.

3. Why I process your data (our legal basis)

I use different lawful bases depending on why I am processing your information.

• Consent – for newsletter emails and, where applicable, for recording and transcribing coaching conversations using Fathom. You can withdraw consent at any time.

• Contract or steps before entering into a contract – for processing information needed to arrange and deliver coaching or another service you have requested, including appointment details, contact details, Zoom links and information needed to issue an invoice.

• Legal obligation – where I need to keep or use certain information to comply with legal or regulatory requirements, including accounting and tax record-keeping requirements.

• Legitimate interests – for reasonable business administration and management, such as maintaining business records, managing enquiries, protecting my systems and running the business, provided this does not override your rights and freedoms.

If I ever need to process special-category data beyond information you choose to share during a coaching conversation, I will ensure that the appropriate legal requirements and additional conditions under UK data protection law are met.

4. How I collect your data

I collect personal data directly from you when you:

• sign up to my newsletter, for example through a sign-up form on my website;

• make an enquiry or contact me;

• book or take part in coaching or another service; or

• request a physical resource.

I do not buy personal data lists or sell personal data.

I may receive limited personal data from service providers where this is necessary to administer a service you have requested.

5. Who I share your data with

I use a small number of third-party services to run my business. I only share information that is necessary for them to provide their service to me or to fulfil a service you have requested.

• KIT – to store email addresses and send newsletters.

• Zoom – to provide links and deliver online coaching sessions.

• Fathom – where you give explicit permission, to record and transcribe a coaching conversation. Fathom processes the recording and transcript on my behalf.

• Xero – to issue invoices and maintain financial records.

• Amazon or another appropriate retailer – where you ask me to arrange delivery of a physical resource, I may provide the name and delivery address needed to fulfil that request.

• Egnyte – to securely store business files and records.

• Roadmap-IT – my external IT support provider, who may need limited access to systems in order to maintain and support my IT and security.

I may also share information where required by law, to protect my legal rights, or where necessary to prevent fraud or other unlawful activity.

I run a private group for a small number of clients. When emailing the group as a whole, I use BCC so that members' email addresses are not visible to each other.

I do not sell or rent your personal data and I do not share it with other companies for their own marketing purposes.

6. International data transfers

Some of the service providers I use may process or store personal data outside the UK.

Fathom states that its data is stored in the United States. For UK customers, Fathom states that it can enter into a data processing agreement and uses appropriate safeguards for international data transfers.

Where personal data is transferred outside the UK, I will ensure that the transfer is made in accordance with UK data protection law and that an appropriate transfer mechanism or safeguard is in place. Depending on the destination and provider, this may include a UK adequacy regulation, the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism.

I will take reasonable steps to ensure that the providers I use have appropriate security and privacy arrangements in place.

7. How long I keep your data

I do not keep personal data indefinitely and aim to retain only what I need for as long as I need it.

• Newsletter data: kept for as long as you remain subscribed. When you unsubscribe, your information will be removed or suppressed from future marketing, subject to any information I need to retain for legitimate business or legal purposes.

• Coaching and booking information: Booking information is kept for as long as reasonably necessary to provide and manage the service, maintain appropriate business records and deal with any legal or contractual matters. Brief client notes are retained only for the duration of the client/coach relationship and securely deleted when our work together ends, subject to any information I may need to retain to meet legal or contractual obligations.

• Fathom recordings and transcripts: Where a coaching conversation is recorded with your permission, the recording and transcript are retained only for the duration of the client/coach relationship and securely deleted when our work together ends.

• Financial and invoice records: retained for as long as required by applicable accounting and tax requirements.

• Home or delivery address: kept only for as long as needed to arrange delivery, unless there is another lawful reason to retain it.

8. Your rights

Under UK data protection law, you may have the right to:

• access the personal data I hold about you;

• ask me to correct inaccurate or incomplete data;

• ask for your data to be erased, where applicable;

• ask me to restrict or object to certain processing;

• withdraw your consent where I rely on consent;

• request data portability where that right applies; and

• complain about how I have handled your personal data.

To exercise your rights, contact me using the details in Section 1.

I will normally respond to a valid rights request within one month. In some circumstances, the law allows this period to be extended or paused, and I may need further information from you to deal with a request securely.

How to complain to me

If you are unhappy about how I have handled your personal data, you can complain to me directly. You do not need to complain to the ICO first.

Please email kate@anchorscoaching.co.uk with "Data protection complaint" in the subject line and explain what has happened.

I will acknowledge your complaint within 30 days, take appropriate steps to investigate it, keep you informed where appropriate, and tell you the outcome without undue delay.

You can also complain to the Information Commissioner's Office (ICO):

Website: ico.org.uk

Helpline: 0303 123 1113

9. Keeping your data secure

I take reasonable technical and organisational measures to protect personal data against loss, misuse, unauthorised access, alteration or disclosure.

These measures include:

• storing business files and records securely on Egnyte, protected by two-factor authentication (2FA);

• using reputable, password-protected third-party platforms for email, video calling and invoicing;

• using Fathom only with your permission and keeping recording/transcription access appropriately restricted;

• working with an external IT support team, Roadmap-IT, to manage and monitor my IT security; and

• limiting the personal data I collect and retain, including not holding bank or payment card details and only retaining delivery addresses where needed.

If a personal data breach occurs, I will assess it promptly and take appropriate action, including notifying affected individuals and/or the ICO where required by law.

10. Changes to this policy

I may update this policy from time to time, for example if I change the services or technology I use, my data processing activities or the law that applies.

The date at the top of this policy shows when it was last updated.

I will make the current version available through my website.