Privacy Notice
Effective from: 29/09/26
Last updated: 29/09/26
1. About this Privacy Notice
This Privacy Notice explains how I collect, use, store and protect personal information in connection with my coaching practice.
It applies to:
I am committed to handling personal information responsibly, respectfully and transparently.
This Privacy Notice should be read alongside my Coaching Agreement, Professional Standards & Ethics Statement and, where applicable, my Three-Party Executive Coaching Agreement.
2. Who I am
Coach/business name: David Baker / Teamed C & C UK Ltd
Business address: 22, Lane Ends, Halifax. HX3 7SD
Email: david@teameduk.net
Website: www.teameduk.net
For UK data-protection purposes, I am the data controllerfor the personal information I process in connection with my coaching business, except where the law or a particular contractual arrangement provides otherwise.
I am responsible for determining why and how personal information is processed within my coaching practice.
I am not currently required to appoint a Data Protection Officer.
3. What personal information I may collect
Depending on the nature of our relationship, I may collect and use:
Contact and identification information
Coaching and professional information
This may include information you choose to discuss during coaching, such as:
I aim to collect and retain only information that is reasonably necessary for the purposes for which it is being used. This reflects the data-protection principles of purpose limitation and data minimisation.
Administrative and financial information
Where applicable, I may process:
I do not normally need to see or retain your full payment-card details where payment is made through a third-party payment provider.
4. Cookies
Our website uses cookies to differentiate you from other users. This helps us to provide a smooth and secure browsing experience, prevent fraud, enhance security, and make improvements to our services. In some cases, cookies may also be used to collect aggregated, statistical information about our services for analytical purposes.
5. Information discussed during coaching
Coaching is a confidential professional relationship.
Information you choose to share during coaching may include personal, professional or sensitive information.
I will treat information shared in coaching with appropriate confidentiality and will not routinely disclose the substance of your coaching conversations to third parties.
However, confidentiality and data protection are not exactly the same thing. This Privacy Notice explains how personal information is processed; the Coaching Agreement explains the professional confidentiality arrangements applying to the coaching relationship.
For business-sponsored coaching, the arrangements concerning what may be shared with the sponsoring organisation are set out separately in the applicable coaching agreement.
6. Business-sponsored and executive coaching
Where an organisation commissions and/or pays for coaching for an individual, I may receive information from the organisation such as:
The sponsoring organisation does not automatically receive the substance of your coaching conversations.
Unless otherwise specifically agreed, information that may be shared with the sponsor may include matters such as:
The precise arrangements will be established during the initial contracting process and recorded in the applicable coaching agreement.
Where appropriate, three-way review meetings involving the coach, coachee and sponsor may be used instead of providing detailed reports about individual coaching sessions.
7. Special category information
Some information that may arise in coaching is treated as special category data under UK data-protection law. Examples include information concerning health, racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, genetic or biometric information, and information concerning sex life or sexual orientation.
I do not routinely require special category informationin order to provide coaching.
If you choose to disclose such information during coaching, I will seek to minimise the information I record and retain.
Where I need to process special category information, I will ensure that both an appropriate Article 6 lawful basis and an applicable Article 9 condition are identified. The ICO confirms that both are required when special category information is processed.
Where appropriate, this may include relying on explicit consent. Consent will not be requested routinely simply because information happens to be discussed during coaching; the appropriate legal basis depends on the particular processing activity.
8. Why I use personal information
I use personal information for purposes including:
Providing coaching
To:
Managing my business
To:
Professional practice
To:
Where information is discussed for supervision or reflective practice, I will take reasonable steps to minimise identifying information where practicable.
Legal and regulatory purposes
To:
Marketing
If I send marketing communications, I will do so in accordance with applicable data-protection and electronic-marketing requirements.
Where consent is required, I will ask for it separately and provide an appropriate way to withdraw it.
9. My lawful bases for processing
UK data-protection law requires me to identify a lawful basis before processing personal information. The appropriate basis depends upon the particular purpose for which the information is being processed.
The main lawful bases I may rely upon are:
Purpose
Lawful basis
Responding to an enquiry and taking steps towards providing coaching
Contract / steps prior to entering into a contract
Providing and administering coaching
Contract
Managing appointments and communications
Contract and/or legitimate interests, depending on circumstances
Administering business-sponsored coaching
Contract and/or legitimate interests, depending on the relationship
Maintaining appropriate professional records
Legitimate interests
Professional supervision and reflective practice
Legitimate interests
Maintaining business and financial records
Legal obligation and/or legitimate interests, as applicable
Establishing, exercising or defending legal claims
Legitimate interests and/or legal obligation, as applicable
Direct marketing
Consent where required, or another lawful basis where legally available
Processing special category information
An Article 6 lawful basis together with an applicable Article 9 condition
Where I rely on legitimate interests, those interests may include running and administering my coaching practice, maintaining appropriate professional standards, protecting my business and clients, maintaining professional records, and establishing or defending legal claims.
The ICO states that organisations relying on legitimate interests should explain the legitimate interests being pursued in their privacy information.
I will not use personal information for a new or incompatible purpose without considering the applicable data-protection requirements and, where necessary, providing further information or obtaining consent.
10. Where personal information comes from
I will normally collect personal information directly from you.
However, in business-sponsored coaching, information may also be provided by:
Where I receive personal information from another source, I will provide appropriate privacy information in accordance with applicable requirements. The ICO states that where personal information is obtained from another source, privacy information will generally need to be provided within a reasonable period and no later than one month, subject to applicable exceptions.
11. Who I may share personal information with
I will only share personal information where there is an appropriate reason and lawful basis for doing so.
Depending on the circumstances, this may include:
Professional supervisor
I may discuss aspects of my professional practice with a coaching supervisor.
Where possible, I will minimise identifying information and maintain appropriate professional confidentiality.
Professional advisers
I may share relevant information with professional advisers such as:
I will only provide information reasonably necessary for the relevant purpose.
Technology and service providers
I use technology and service providers to operate my coaching business.
My principal business technology environment is Microsoft 365, including:
Microsoft processes customer data under its applicable contractual terms and Data Protection Addendum. Microsoft's current DPA is dated May 2026.
Sponsoring organisations
Where coaching is commissioned by an organisation, information may be shared with the sponsor in accordance with the applicable Three-Party Executive Coaching Agreement and agreed information-sharing arrangements.
Legal or regulatory authorities
I may disclose information where I am legally required or permitted to do so.
This may include circumstances involving legal proceedings, statutory obligations or circumstances where disclosure is necessary to protect someone's vital interests or prevent serious harm, subject to applicable law.
12. Microsoft 365
I use Microsoft 365 as an important part of my business technology environment.
Outlook
I use Outlook for:
Microsoft Teams
I use Teams for:
Teams data is associated with the geographic region of the relevant Microsoft 365 organisation. Microsoft also provides specific data-residency commitments for UK tenants and certain Microsoft 365 core services.
Microsoft Word and Excel
I may use Word and Excel for:
I will seek to use these applications in a way that is proportionate to the purpose for which information is being processed.
13. International transfers
Some technology and service providers may process or provide access to personal information from locations outside the UK.
Microsoft provides data-residency commitments for certain Microsoft 365 customer data stored at rest in the UK, but this does not mean that every form of processing, support access or transfer necessarily takes place exclusively within the UK.
Where UK data-protection law requires safeguards for a restricted international transfer, I will ensure that an appropriate transfer mechanism or safeguard is in place.
The ICO's current guidance provides for various appropriate safeguards for international transfers, including the UK International Data Transfer Agreement and UK Addendum where applicable.
14. Security
I take reasonable technical and organisational measures to protect personal information against:
Measures may include appropriate:
No electronic system can be guaranteed to be completely secure. I will nevertheless take reasonable and proportionate steps to protect the information I hold.
15. Online coaching
Where coaching is provided through Microsoft Teams:
Clients are also asked to take reasonable steps to participate from an environment where confidentiality can be maintained.
16. Artificial intelligence
I recognise that artificial-intelligence features are increasingly incorporated into software and business applications.
I do not routinely need to use generative AI to provide coaching.
I will not knowingly submit identifiable confidential coaching information to a public generative-AI service for processing without first considering confidentiality, data protection, security and the applicable lawful basis.
Where an AI-enabled feature is used in connection with business or administrative information, I will remain responsible for deciding whether its use is appropriate.
AI-generated material will not replace my professional judgement.
17. Coaching notes and professional records
I may make limited notes to support:
I will aim to keep coaching notes proportionate and relevant rather than creating unnecessary detailed records of conversations.
I will not create a transcript of coaching sessions unless there is a specific reason to do so and the appropriate arrangements have been established.
18. How long I keep personal information
I will not keep personal information for longer than is reasonably necessary for the purpose for which it was collected, taking account of legal, professional, contractual and legitimate business requirements.
My current retention approach is:
Type of information
Proposed retention period
Enquiry and contact information
Normally up to 3 years after the last meaningful contact, unless a longer period is justified
Coaching notes
Normally up to 3 years after the coaching relationship ends
Coaching agreements
Normally 6 years after the relationship ends
Business/financial records
In accordance with applicable tax and accounting requirements
Records relating to complaints or disputes
Normally up to 6 years after resolution, or longer where reasonably necessary
Marketing records
Until consent is withdrawn or the information is otherwise no longer required, subject to maintaining appropriate suppression records
These periods are not intended to override a legal requirement to retain information for a different period, or to require deletion where information is reasonably necessary for an ongoing legal claim or dispute.
I will periodically review retained information and securely delete or anonymise information that is no longer required.
The ICO's current guidance emphasises that organisations should not retain personal information for longer than necessary and should have a justified retention approach.
19. Your data-protection rights
Depending on the circumstances and applicable legal exemptions, you may have rights concerning your personal information, including the right to:
These rights are not all absolute and may depend upon the lawful basis for processing and the particular circumstances.
For example, the ICO explains that the availability of rights such as erasure, portability and objection can depend upon the lawful basis being relied upon.
20. How to exercise your rights
If you wish to exercise a data-protection right or ask a question about how I use your information, please contact us via our contact form on the website, or via email: david@teameduk.net
I may need to confirm your identity before responding to a request.
I will deal with requests in accordance with applicable data-protection requirements.
21. Complaints about data protection
I hope that you will contact me first if you have a concern about how I have handled your personal information so that I have an opportunity to address it.
You also have the right to complain to the UK's data-protection regulator:
Information Commissioner's Office (ICO)
Website: Information Commissioner's Office
The ICO provides information about data-protection rights and how to make a complaint.
22. Confidentiality, safeguarding and serious risk
My coaching practice is based on respect for client autonomy, privacy and confidentiality.
There may nevertheless be circumstances in which information needs to be disclosed, including where:
The precise confidentiality arrangements applying to a coaching relationship are set out in the relevant Coaching Agreement.
23. Professional standards
I am a City & Guilds/ILM Level 7 qualified Executive and Senior Level Coach and Mentor, holding the:
City & Guilds Level 7 Certificate for Executive and Senior Level Coaches and Mentors
Qualification number (QAN): 603/3762/X
My professional practice is informed by the Global Code of Ethics for Coaches, Mentors and Supervisors and by principles including:
Use of an ethical framework does not itself represent membership or accreditation by any particular professional body.
24. Changes to this Privacy Notice
I may update this Privacy Notice from time to time to reflect:
The latest version will be made available through www.teameduk.net
Where a change materially affects how I use personal information, I will provide appropriate information before introducing the new processing where required.
The ICO expects privacy information to be reviewed and updated where necessary, particularly where new uses of personal information are introduced.
25. Contact
Questions, comments and requests regarding this privacy policy are welcomed using our contact form via www.teameduk.net
Privacy Notice version: 26/1
Effective date: 29/06/26
Last reviewed: 29/06/26
Next review: 28/06/27
We use cookies to analyze website traffic and optimize your website experience. By accepting our use of cookies, your data will be aggregated with all other user data.