Privacy Policy

I am committed to respecting and protecting the security of your personal information, and to being transparent about the information I hold about you. This policy explains how I collect and use your personal information during and after our professional coaching relationship. I use the information I collect about you in accordance with the General Data Protection Regulation (GDPR).

Any reference to ‘I’ or ‘me’ shall mean Candice Powdrill as a sole trader.

Any reference to ‘you’ shall mean any individual receiving this notice for whom I hold personal data. This will usually relate to clients, but also includes individuals with whom I have spoken in person or who have contacted me via telephone or online, and who have expressed interest in my services.

Clients should consider this Privacy Policy as a supplement to the Contractual Agreement between Client and Coach.

I comply with data protection laws including GDPR. This says that the personal information I hold about you must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that I have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes I have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only if necessary for the purposes I have told you about.
• Kept securely.
  

Information I may collect about you

Personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, i.e. anonymous data.

I will collect, store, and use the following types of personal information:

• Identity data including first name, last name, title, date of birth and gender.
• Contact details including address, email address and telephone number.
• Who should be contacted in case of emergency or safety concerns, and contact details for the nominated person/s.
• Transaction Data including details about payments from you for my services.
• Details of services purchased from me.
• Your preferences in receiving any marketing material from me (i.e. newsletter) and communication preferences.
  

During the coaching process, I keep notes of each session to track clients’ progress. These will include full details of the coaching process, information/suggestions given by me, results of coaching and any follow-up given where appropriate. These notes are coded (anonymized) to ensure client confidentiality (i.e. no personal information is included), but will remain identifiable by me. Session notes are filed separately to any records containing personal information. All records are securely stored.

Due to the nature of the coaching relationship and coaching process, you may choose to disclose sensitive data, considered Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health and genetic and biometric data). If it is necessary to hold any such information to support the coaching process, it will be included only on your anonymized session notes and stored securely separately from any personal information.

If you undertake Email Coaching with me, this correspondence will be sent to my dedicated email address with an encrypted account. This account is password protected and accessed only from my personal device. I strongly suggest that you also set up an encrypted account for this purpose, which will keep our coaching correspondence separate from your personal information. The content of email coaching correspondence will be treated equally to session notes and retained accordingly.

How I collect your information

I collect information directly from you when you contact or speak with me either in person, through my website or social media, or by email or phone. I collect information from you when we enter into a coaching relationship, and when you disclose information during the coaching relationship.

If you fail to provide personal information

If you fail to provide certain information when requested, I may not be able to perform the contract I have entered with you or am trying to enter into with you (i.e. arranging coaching session/s). In this case, I may need to cancel any arrangements with you.

Your duty to inform me of changes

It is important that the personal information I hold about you is accurate and current. Please keep me informed if your personal information changes during your working relationship with me.

How I use your information

I will only use your information where the law allows me to do so. This includes the following circumstances:

• Where I need to perform the contract I have entered into with you.
• Where I need to comply with a legal obligation.
• Where it is necessary for my legitimate interests and your interests and fundamental rights do not override those interests.
  

I may use your personal information for the following purposes: 

• To respond to you if you contact me with a query. 
• To register you as a client and complete our contractual agreement.
• To carry out coaching sessions as arranged with you. 
• To arrange and manage payment for my services.
• To notify you of any changes to my services, terms, prices or policies.
• To ask you to leave a review of my services. 
• To administer and protect my business. 
• To make suggestions and recommendations to you about services that may be of interest to you.
  

In rare instances I may need to use your personal information for the following purposes: 

• Where I need to protect your interests (or someone else’s interests).
• Where it is needed in the public interest (or for official purposes).
• To deal with any legal dispute involving you. 

The details of the person/s nominated as your emergency contact will only be used in the case of legitimate concern for your safety or the safety or others, and shall not be processed for any other purpose. In such circumstances I will need to share your information with the nominated person/s.

Marketing Communications

I endeavour to contact you with information about my services in ways that you find relevant, respectful and not excessive. 

If you are a current or previous client, or have spoken to or contacted me regarding my services, I may use the contact details provided by you to send information and updates relating to my services, including newsletters, if I believe this relates to your interests. It is within legitimate business interests to send any such marketing communications. 

You have the right to ask me to erase or rectify your data and you have the right to opt out of receiving marketing information I think might be of interest to you.

Disclosure of your details to third parties

I may share your personal information with third parties in the following circumstances:

• To service providers who process data on my behalf and on my instructions. This includes BoldSign electronic signature provider in order to complete our contractual agreement (https://boldsign.com/security-policy/) and SumUp payment processing provider in order to arrange and manage payment for my services (https://www.sumup.com/en-gb/privacy/)
• Where I am under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies). 
• Where I have legitimate reason to believe there is risk of harm to yourself or someone else. 
• Where necessary to administer the needs of my business or for legal purposes.
  

Security of your personal information 

All personal information held by me is securely stored with appropriate safeguards in place. 

I do not take any responsibility for any breach of data, privacy or confidentiality occurring due to the use of video link technology. Please refer to the privacy policy of the relevant service.

The transmission of information via the internet is not completely secure. I cannot guarantee the security of your data transmitted online and transmission is made at your own risk. If you communicate with me by email you assume the risks of such communications being intercepted, not received, or received by persons other than the intended recipient.

Security of your financial information

If you wish to use your credit or debit card to make a payment for my services, I will arrange for payment to be made through my chosen payment processing provider, SumUp, which operates in accordance with the Payment Card Industry Data Security Standard (PCI-DSS). Please refer to the privacy policy of this service for further information: https://www.sumup.com/en-gb/privacy

Data Retention

I will only retain your personal information for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.

In respect to clients’ personal information and the corresponding coded session notes, this data will be held for 7 years from the date of the final session of the coaching relationship. I have a legitimate business interest in retaining the data for this period should any subsequent legal proceedings ensue.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to

your personal information, as follows:-

• Request access to your personal information
  You have a right to request a copy of the personal information I hold about you. Please contact me if you wish to do so. 
• Request correction of your personal information
  You have the right to request that I correct the personal information I hold about you.
• Request erasure of your personal information
  You have the right to request that I delete or remove personal information where there is no good reason for me to continue to process it. Please note that I may not always be able to comply with your request for erasure if there are specific legal reasons, including the requirement by my insurance company for me to retain client records for at least 7 years.
• Object to processing of your personal information
  You have the right to object to the processing of your personal information where I am relying on a legitimate interest and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where I am processing your personal information for direct marketing purposes.
• Request restriction of processing your personal information
  You have the right to request that I suspend the processing of your personal data in some scenarios, including if you want me to establish the data’s accuracy; you wish me to stop processing your data but you do not want me to erase it; where you need me to hold the data even if I no longer require it.
• Request transfer of your personal information
  You have the right to request that the personal information I hold about you is transferred to you or to a third party.
• Right to withdraw consent
  In circumstances where I am relying on your consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide my services to you. I will advise you if this is the case at the time you withdraw your consent.
  

Please also note the following:

• No fee usually required
  You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, I may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, I may refuse to comply with the request in such circumstances.
• What I may need from you
  I may need to request specific information from you to help confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
• Time limit to respond
  I will try to respond to all legitimate requests within one month. Occasionally it may take longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.

Changes to this privacy policy

I reserve the right to update this privacy notice at any time. I will provide a new privacy notice when I make any substantial updates.

Contact details and further information

The Data Controller is Candice Powdrill.

Please contact me by email if you would like to exercise any of the rights outlined in this policy, have any questions about the information I hold about you, or would like to change your contact preferences. 

Please contact me if you have any questions about any aspect of this privacy policy. 

You can visit the website for the Information Commissioner’s Office https://ico.org.uk/ for further information or if you wish to make a complaint. 

This Privacy Policy was last updated on 08 May 2025.