Privacy Policy
This privacy notice tells you what to expect us to do with your personal information.
- Contact details
- What information we collect, use, and why
- Lawful bases and data protection rights
- Where we get personal information from
- How long we keep information
- How to complain
Contact details:
Telephone: 07876 444450
Email: paulkelly@tywysyddcoaching.co.uk
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
- Names and contact details
- Addresses
- Gender
- Pronoun preferences
- Occupation
- Information relating to compliments or complaints
- Website user information
We collect or use the following personal information for the operation of client or customer accounts:
- Names and contact details
- Addresses
- Purchase or service history
- Information used for security purposes
We collect or use the following personal information for information updates or marketing purposes:
- Names and contact details
We collect or use the following personal information for research or archiving purposes:
- Names and contact details
We collect or use the following personal information to comply with legal requirements:
- Name
- Contact information
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Addresses
- Account information
- Purchase or service history
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
- Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
- Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
- Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
- Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
- Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
- Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
- Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Our lawful bases for collecting or using personal information for research or archiving purposes:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Our lawful bases for collecting or using personal information to comply with legal requirements:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
- Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Where we get personal information from
- Directly from you
- Publicly available sources
How long we keep information
For information on how long we keep personal information, see our retention schedule at www.tywysyddcoaching.co.uk
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
Last updated
7th October 2025
Data Retention Policy
Data Retention Policy (UK)
Organisation: Tywysydd Coaching
Effective Date: 07/10/2025
Version: 1.0
Approved by: Paul Kelly
1. Purpose
This policy sets out how [Your Company Name] retains, stores, and securely disposes of personal data in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. As an executive coaching provider, we collect and manage personal data from clients, suppliers, and partners. This policy ensures such data is kept only as long as necessary and securely deleted when no longer required.
2. Scope
This policy applies to all personal data handled by the business, including information about:
- Clients (coaching participants and corporate clients)
- Prospective clients (marketing leads)
- Contractors, associates, and suppliers
- Employees (if applicable)
It applies to both digital and paper records.
3. Legal Basis
We retain personal data only for as long as necessary to:
- Deliver coaching services
- Comply with legal, tax, and contractual obligations
- Resolve disputes and maintain business records
The policy follows the data minimisation and storage limitation principles under Article 5(1)(c) and (e) of the UK GDPR.
4. Responsibilities
- Data Protection Lead: [Name or Role] – responsible for implementing and monitoring this policy.
- All team members and contractors must ensure data is securely managed and disposed of according to this policy.
5. Data Retention Schedule
Data Category
Retention Period
Reason / Legal Basis
Disposal Method
Client contact details, session notes, and contracts
6 years after final session
Limitation Act 1980 (contractual claims)
Secure digital deletion or shredding
Coaching session recordings or transcripts (if used)
12 months (unless required longer by client agreement)
Service delivery
Secure deletion
Financial and invoicing records
6 years
HMRC requirements
Secure deletion
Marketing enquiries / mailing list data
Until consent withdrawn or 2 years of inactivity
Consent (Art. 6(1)(a))
Permanent deletion
Supplier and associate contracts
6 years after end of relationship
Contractual necessity
Secure deletion
Employee or contractor HR records (if applicable)
6 years after leaving
Employment law
Secure deletion
Website contact form submissions
12 months
Business development
Secure deletion
Retention may be extended if required for legal or regulatory reasons.
6. Data Review and Disposal
Data will be reviewed annually. When data reaches the end of its retention period, it will be securely deleted or destroyed so that it cannot be reconstructed.
- Digital data: Permanently erased from devices and cloud systems.
- Paper records: Shredded or securely destroyed by approved providers.
7. Data Storage and Security
All personal data is stored securely using password-protected systems and encrypted storage. Only authorised personnel and contractors have access to personal data required for their work. Cloud services used must comply with UK GDPR standards and, where relevant, UK adequacy decisions.
8. Exceptions
If data must be retained beyond the normal retention period (e.g., due to an ongoing dispute or client request), the reason and duration must be documented and approved by the Data Protection Lead.
9. Policy Review
This policy will be reviewed annually or sooner if required by changes in legislation or business operations.
10. Related Documents
- Privacy Notice
- Data Protection Policy
- Data Breach Response Procedure
