ERT Enterprises Ltd Trading as Thorp Coaching Privacy Policy
Name: Emma Thorp
Address: Lavender Cottage, Nutley, TN22 3LL
Phone Number: 07866719867
E-mail: emma.thorp@thorpcoaching.com
Website: www.thorpcoaching.com
Privacy Policy – ERT Enterprises Ltd Trading as Thorp Coaching
1. Introduction
Thorp Coaching is committed to protecting your personal data and handling it responsibly and transparently. This policy explains how personal data is collected, used and stored in line with UK GDPR and the Data Protection Act 2018.
2. Who we are
Thorp Coaching is the data controller for the purposes of this policy.
Contact: emma.thorp@thorpcoaching.com
Website: www.thorpcoaching.com
Thorp Coaching is registered with the Information Commissioner’s Office (ICO).
Registration number: ZA607156
3. The data we collect
We may collect and process the following types of personal data:
Contact details (name, email address, phone number, company details)
Communication data (emails, messages, WhatsApp messages, enquiry forms)
Coaching engagement data (session scheduling, attendance, general progress information)
Where relevant to the delivery of coaching, retreats, or associated services, we may also process:
Coaching notes and reflective information
Wellbeing or accessibility information voluntarily shared by the client or coachee
Emergency contact details, dietary requirements or allergy information for retreat delivery
Session recordings or transcriptions (only where explicitly agreed in advance)
We do not require sensitive personal data unless it is directly relevant to delivering the service and it is always provided voluntarily.
4. How we collect data
Data may be collected through:
Website enquiries or contact forms
Direct communication (email, phone, WhatsApp messaging)
Booking systems and scheduling tools
During coaching sessions or programme delivery
5. How we use your data
We use personal data to:
Respond to enquiries and manage relationships
Deliver coaching, retreats and associated services
Manage scheduling, logistics and administration
Maintain appropriate records of coaching engagements
Ensure safe delivery of retreats and in-person experiences
For corporate engagements, personal data may be used to manage the relationship with the sponsoring organisation, in line with agreed confidentiality boundaries.
6. Lawful basis for processing
We process personal data under the following lawful bases:
Contract – where processing is necessary to deliver agreed services
Legitimate interests – to manage and improve services and relationships
Consent – where required (for example, for recordings, transcription, or use of specific tools)
Where any special category data (such as health or wellbeing information) is processed, this is done only where voluntarily provided and where necessary for service delivery, with appropriate safeguards in place.
7. Confidentiality and coaching engagements
Coaching conversations are treated as confidential.
For corporate coaching engagements:
Confidentiality is maintained between coach and coachee
Sponsors will only receive high-level, non-confidential updates where explicitly agreed in advance
No personal or sensitive information is shared without the coachee’s knowledge and agreement, unless legally required
8. Third-party providers and tools
We use trusted third-party providers to support the delivery of our services. These include:
Google Drive (via Google Workspace) for secure storage and document management
Otter.ai for note-taking or transcription, where explicitly agreed in advance
WhatsApp for communication, where preferred by the client
Where Otter.ai or similar tools are used, this will always be on an opt-in basis and agreed with the client or coachee in advance.
These providers act as data processors and are required to maintain appropriate security and data protection standards.
Where data is processed outside the UK, appropriate safeguards are in place in line with UK GDPR requirements.
9. Data storage and security
Personal data is stored securely using Google Drive (via Google Workspace) and other secure, cloud-based systems with appropriate access controls and authentication measures.
Access to data is restricted to authorised individuals only
Strong passwords and two-factor authentication are used where available
Devices used to access data are secured and access-controlled
Coaching notes may be taken during sessions and are stored digitally within secure systems.
We do not retain paper-based coaching notes. Any temporary handwritten notes are digitised and securely destroyed.
10. Data retention
Personal data is retained only for as long as necessary to fulfil the purpose it was collected for, including:
Delivering services
Meeting legal, tax, or insurance requirements
Typical retention periods are up to 6 years following the end of an engagement, unless a longer period is required or agreed.
11. Sharing of data
We do not sell or trade personal data.
Data may be shared only where necessary with:
Service providers supporting delivery (as outlined above)
Professional advisers (e.g. legal, accounting) where required
Regulatory or legal authorities if legally required
Any sharing is limited to what is necessary and proportionate.
12. Your rights
You have the right to:
Access the personal data we hold about you
Request correction of inaccurate data
Request deletion of your data where appropriate
Object to or restrict processing
Withdraw consent where processing is based on consent
Requests can be made via emma.thorp@thorpcoaching.com
13. Changes to this policy
This policy may be updated from time to time to reflect changes in practice or legal requirements. The most current version will always be available on the website.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at emma.thorp@thorpcoaching.com
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
