Privacy Policy

ERT Enterprises Ltd trading as Thorp Coaching

Name: Emma Thorp
Address: Lavender Cottage, Nutley, TN22 3LL
Phone: 07866 719867
Email: emma.thorp@thorpcoaching.com
Website: www.thorpcoaching.com

1. Introduction

Thorp Coaching is committed to protecting your personal data and handling it responsibly, fairly and transparently. This policy explains what personal data we collect, how and why we use it, who it may be shared with, how long it is retained and the rights available to you under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Who we are

ERT Enterprises Ltd, trading as Thorp Coaching, is the data controller for the personal data covered by this policy.

You can contact us at:

Thorp Coaching is registered with the Information Commissioner’s Office (ICO). Registration number: ZA607156.

3. The personal data we collect

We may collect and process:

  • Contact details, including your name, email address, phone number and company details.

  • Professional information, including your organisation, role and relevant professional interests.

  • Communication data, including emails, messages, WhatsApp messages, enquiry forms and relevant business correspondence.

  • Coaching engagement data, including scheduling, attendance, agreed objectives and general progress information.

  • Transaction and administrative information needed to manage contracts, invoicing and payment.

  • Technical and website-use information collected through our website and associated cookies or similar technologies, where applicable.

Where relevant to coaching, retreats or associated services, we may also process:

  • Coaching notes and reflective information.

  • Wellbeing, health, diagnostic or accessibility information voluntarily shared by a client or coachee.

  • Emergency-contact details, dietary requirements or allergy information needed for safe retreat delivery.

  • Session recordings or transcriptions, but only where this has been explicitly agreed in advance.

We do not require sensitive personal data unless it is directly relevant to delivering the service or meeting an agreed need. Clients are not expected to provide more information than is necessary.

4. How we collect personal data

We may collect personal data:

  • Directly from you through enquiries, emails, phone calls, WhatsApp messages, forms or conversations.

  • Through booking, scheduling, payment or administrative systems.

  • During coaching sessions, retreats or programme delivery.

  • From a sponsoring organisation where it is arranging or funding an engagement.

  • Through professional introductions or referrals.

  • From publicly available professional sources, such as an organisation’s website or a professional networking profile, where relevant to legitimate business-development activity.

  • Through our website and its associated technical systems, cookies or analytics, where applicable.

Where information is supplied by a sponsoring organisation, we will maintain the agreed confidentiality boundary between the sponsor, coach and coachee.

5. How we use personal data

We use personal data to:

  • Respond to enquiries and manage professional relationships.

  • Deliver coaching, retreats, workshops and associated services.

  • Agree objectives, manage engagements and maintain appropriate records.

  • Manage scheduling, logistics, contracts, invoicing and administration.

  • Ensure the safe delivery of retreats and in-person experiences.

  • Communicate about relevant Thorp Coaching services, events or opportunities where permitted.

  • Meet legal, regulatory, tax, insurance and safeguarding obligations.

For corporate engagements, personal data may be used to manage the relationship with the sponsoring organisation, in line with the confidentiality arrangements agreed with the coachee and sponsor.

Approved AI-enabled tools may be used for limited business administration, research, drafting, design and professional relationship management. This may involve limited professional contact information, such as a person’s name, organisation, role and the status or relevant content of business correspondence.

AI may also be used to organise the wording of coaching themes and actions only after the information has been reduced to broad, non-identifying terms and sensitive or distinctive details have been removed. General-purpose AI tools are not used to process raw or identifiable coaching notes, recordings, transcripts, assessments or sensitive client information. They are not used to make automated decisions about clients or coachees.

Further information is available in our AI Policy: https://thorpcoaching.com/ai-policy.

6. Lawful basis for processing

We process personal data under one or more of the following lawful bases:

  • Contract: where processing is necessary to provide an agreed service or take requested steps before entering into a contract.

  • Legitimate interests: where processing is necessary and proportionate for managing the practice, responding to enquiries, carrying out relevant business-development activity, maintaining professional relationships, improving services and carrying out appropriate administration.

  • Consent: where consent is appropriate or required, including for optional recording or transcription and for electronic marketing where consent is required.

  • Legal obligation: where processing is necessary to meet legal, tax, insurance, regulatory or safeguarding obligations.

Business-development outreach is limited to relevant professional contacts and carried out in accordance with applicable electronic-marketing and data-protection rules. Where required, we obtain consent or provide an appropriate opportunity to opt out. We do not use confidential coaching information, sensitive personal information or information identifying someone as a coaching client for business-development outreach.

Where we process special-category data, such as health, diagnostic, wellbeing or accessibility information, we also identify an appropriate condition under Article 9 of the UK GDPR. Where relevant information is voluntarily provided so that we can tailor coaching, make adjustments or deliver a retreat safely, we will normally rely on the individual’s explicit consent. In limited circumstances, a different Article 9 condition may apply, such as where processing is necessary to establish, exercise or defend legal claims.

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing already carried out lawfully before consent was withdrawn.

Thorp Coaching does not make solely automated decisions about clients or coachees that produce legal or similarly significant effects.

7. Confidentiality and coaching engagements

Coaching conversations are treated as confidential.

For corporate coaching engagements:

  • Confidentiality is maintained between coach and coachee.

  • Sponsors receive only high-level, non-confidential information that has been agreed in advance.

  • Personal, sensitive or session-specific information is not shared with a sponsor without the coachee’s knowledge and agreement, unless disclosure is legally required or necessary to address a serious and immediate risk of harm.

The detailed limits of confidentiality are explained in the relevant coaching agreement.

8. Third-party providers and tools

We use selected third-party providers to support the secure and effective operation of the practice. These may include:

  • Google Workspace, including Google Drive: for email, secure storage and document management.

  • Squarespace: for website hosting, website forms and related website services.

  • OpenAI’s ChatGPT: for limited research, drafting, administration, business-development and relationship-management tasks, and for structuring coaching themes and actions only after they have been generalised and stripped of identifying and sensitive information.

  • Google Gemini: for limited research, drafting or administrative support.

  • Canva and selected video-editing tools: for design, marketing and communications.

  • Otter.ai: for optional note-taking or transcription where the client or coachee has actively opted in.

  • WhatsApp: for communication where preferred by the client.

  • Booking, scheduling, payment, accounting or administrative providers used to manage the practice and deliver agreed services.

Only information reasonably necessary for the particular task is made available to a provider. General-purpose AI tools are not given raw or identifiable coaching notes, recordings, transcripts, assessments, health information or detailed accounts of confidential coaching conversations.

Where a provider processes personal data on our behalf, we require appropriate contractual and data-protection arrangements. We review the privacy and security information available for the services we use and use available privacy, security and model-training controls. A client may ask for further information about the tools used in connection with their engagement.

9. Data storage and security

Personal data is stored using Google Workspace and other secure cloud-based systems with appropriate access controls and authentication measures.

We take proportionate measures to protect personal data, including:

  • Restricting access to authorised individuals.

  • Using strong passwords and two-factor authentication where available.

  • Securing and access-controlling the devices used to access personal data.

  • Restricting AI connections to email, documents or other business systems to the information and permissions needed for the defined task.

  • Reviewing AI outputs before they are relied upon, stored or used externally.

Coaching notes may be taken during sessions and stored digitally within secure systems. We do not retain paper-based coaching notes. Any temporary handwritten notes are digitised where needed and securely destroyed.

No method of storage or transmission can be guaranteed to be completely secure, but we take reasonable and proportionate steps to reduce the risk of loss, misuse, unauthorised access or disclosure.

10. International transfers

Some providers may process or store personal data outside the UK. Where this occurs, we review the provider’s transfer arrangements and require an appropriate lawful safeguard, such as applicable adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses or another safeguard permitted under UK data-protection law.

Further information about the safeguards relevant to a particular provider is available on request.

11. Data retention

Personal data is retained only for as long as reasonably necessary for the purpose for which it was collected, including delivering services and meeting legal, tax, regulatory, safeguarding or insurance requirements.

Typical retention periods are:

  • Coaching engagement, contractual and associated administrative records: up to six years following the end of the engagement, unless a longer period is required or specifically agreed.

  • Enquiry and professional relationship information: retained while the relationship or potential business purpose remains relevant and reviewed periodically.

  • Marketing preferences and opt-out information: retained for as long as needed to respect the individual’s communication preference.

  • Recording and transcription data: retained in accordance with the specific arrangements explained when the individual opts in and the current AI Policy.

Working AI prompts and outputs containing limited professional information are retained only for as long as necessary for the task. Where AI has assisted with generalised coaching themes and actions, the working conversation is deleted from the active AI account when the final note has been completed and no later than 30 days afterwards. Provider backups or legally required retention may continue for a limited period following deletion.

Any final coaching note or summary retained by Thorp Coaching is stored within the normal secure client-record system and follows the retention period applicable to the coaching engagement.

12. Sharing personal data

We do not sell or trade personal data.

Personal data may be shared only where necessary and proportionate with:

  • Service providers supporting the operation or delivery of the practice, as outlined above.

  • Associate coaches, facilitators or other delivery partners where they are involved in an engagement and the arrangement has been appropriately disclosed.

  • Professional advisers, such as legal, accounting or insurance advisers, where required.

  • Regulatory, safeguarding or legal authorities where disclosure is required or permitted by law.

  • A sponsoring organisation, but only within the confidentiality boundaries agreed with the coachee and sponsor.

13. Your rights

Depending on the circumstances, you may have the right to:

  • Ask for access to the personal data we hold about you.

  • Ask for inaccurate or incomplete information to be corrected.

  • Ask for your personal data to be deleted where the law permits.

  • Ask us to restrict the processing of your personal data.

  • Object to processing based on legitimate interests or to direct marketing.

  • Ask for certain information to be provided in a portable format.

  • Withdraw consent where processing is based on consent.

  • Ask for information about applicable international-transfer safeguards.

  • Raise a concern with the Information Commissioner’s Office.

These rights are not absolute and may depend on the lawful basis, the information involved and applicable legal or regulatory requirements.

Requests can be made to emma.thorp@thorpcoaching.com. We may need to verify your identity before responding.

14. How to complain

If you have concerns about how we use your personal data, please contact us first at emma.thorp@thorpcoaching.com so that we can try to resolve the issue.

You may also complain to the Information Commissioner’s Office:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline: 0303 123 1113
Website: www.ico.org.uk

15. Changes to this policy

This policy may be updated from time to time to reflect changes in our practice, providers, professional guidance or legal requirements. The most current version will be published on our website.

Last updated: September 2026