Privacy Notice

How I collect, use and protect your personal information

Diana Nerys Hemingway trading as Coaching with Diana
Version 1.1
Last updated: 10 August 2026

1. About this notice

I take your privacy seriously and aim to be open and clear about how I collect, use, store and protect personal information.

This Privacy Notice explains how I handle personal data when you:

visit the Coaching with Diana website
contact me with an enquiry
arrange or attend a discovery call
consider or enter into coaching with me
take part in online or outdoor coaching
communicate with me about coaching or the business
provide feedback or a testimonial
interact with Coaching with Diana in another professional or business context

It also explains your rights and how to contact me if you have any questions or concerns about your personal information.

2. Who I am

I am Diana Nerys Hemingway, a sole trader trading as Coaching with Diana, based in the Isle of Man.

For the personal information described in this notice, I will normally be the Data Controller. This means that I decide why personal information is needed and how it is used.

I am registered with the Isle of Man Information Commissioner under registration number R841969.

You can contact me about data protection or this Privacy Notice at:

Email: diana@coachingwithdiana.co.uk

3. Data protection law

I process personal information primarily in accordance with Isle of Man data protection law, including the Data Protection Act 2018, the Data Protection (Application of the GDPR) Order 2018 and the Applied GDPR.

Where services are offered or provided in circumstances where UK or European data protection law also applies, I will comply with those requirements to the extent that they apply.

I aim to collect only information that is relevant and proportionate to the purpose for which it is needed.

4. What information I may collect

The information I collect will depend on how you interact with me.

Contact and identity information

This may include:

your name
preferred name
email address
telephone number, where relevant
address or country of residence, where relevant

Enquiry and booking information

This may include:

the reason you are contacting me
information you choose to include in an enquiry
discovery call arrangements
appointment dates and times
correspondence about appointments or coaching
how you heard about Coaching with Diana, where you choose to provide this

Pre-coaching suitability information

Before coaching begins, I may ask for information that helps me understand what you are seeking from coaching and whether I can provide the service appropriately, safely and ethically.

This may include:

coaching goals and expectations
current support from healthcare or mental health professionals
whether you are currently participating in therapy or counselling
relevant physical or mental health information that you choose to disclose
accessibility or reasonable adjustment requirements
information relevant to safe participation in outdoor coaching

I do not routinely ask clients to provide a list of medication.

Coaching information

This may include:

coaching goals
information you choose to discuss or provide
brief coaching notes
completed exercises or reflections
agreed actions
attendance and appointment information
correspondence relating to the coaching relationship

Special category information

Some information you choose to provide may be classed as special category personal data, particularly information about physical or mental health.

Additional safeguards apply to this information.

Outdoor coaching information

If you choose outdoor coaching, I may also collect:

information relevant to mobility, accessibility or safe participation
an emergency contact name and contact details
information relating to any accident, injury, near miss or safety incident

Contractual and administrative information

This may include:

coaching agreements
consent records
cancellation or rescheduling information
complaints or concerns
records relating to the administration or termination of coaching

Financial information

This may include:

invoices
payments
payment references
transaction records
information required for accounting or tax purposes

I do not need to retain full payment-card details where payment is processed through a bank or payment provider.

Organisation-funded coaching

Where another organisation funds coaching, I may receive limited personal information from the organisation, such as your name, contact details, eligibility or administrative information required to arrange coaching.

Feedback and testimonials

If you provide feedback, I may retain the feedback and information connected with it.

A testimonial will not be published or used for promotional purposes without your specific permission.

Website and technical information

When you use the website or an online form, limited technical information may be processed by the technology providers used to deliver those services.

5. How I collect information

I may collect personal information:

directly from you
through the Coaching with Diana website
through an enquiry form
by email
during a discovery call
through a pre-coaching questionnaire or other form
during coaching
through Google Meet
through booking, payment or administrative processes
from an organisation funding your coaching
from another person where you have asked them to contact me or where there is another lawful reason for them to provide information

Most of the personal information I use will come directly from you.

6. Pre-coaching suitability and health information

Coaching is intended for people for whom coaching is an appropriate form of support.

Before coaching begins, I may therefore ask limited questions about health or wellbeing where the information is relevant to assessing whether coaching can be provided appropriately, safely and ethically.

For example, I may ask whether you are currently receiving therapy, counselling or other professional support.

You do not have to disclose a diagnosis or provide information that you do not wish to share.

Where I ask you to provide health information as part of the pre-coaching process, I will explain why I am asking for it. Where I rely on explicit consent to process special category health information, that consent will be requested separately and clearly.

You may withdraw consent where consent is the basis on which information is being processed.

However, if I do not have enough relevant information to assess whether coaching can be offered safely and appropriately, I may be unable to begin or continue coaching.

I will only collect health information that I reasonably consider relevant and proportionate.

If health information arises naturally during coaching, I will not routinely create detailed records of it. Any information recorded will be limited to what is reasonably necessary for the coaching relationship, safety, professional obligations or another lawful purpose.

7. Why I use personal information and my lawful bases

Data protection law requires me to have a lawful basis for each purpose for which I process personal information.

Depending on the circumstances, I may rely on the following bases.

Responding to enquiries and arranging discovery calls

I use personal information to respond to enquiries, provide information about coaching and arrange discovery calls.

The lawful basis will normally be taking steps at your request before potentially entering into a contract.

Assessing suitability for coaching

I use relevant information to consider whether coaching is an appropriate service and whether I can provide it safely, ethically and within my competence.

The lawful basis for ordinary personal information will normally be taking steps before entering into a contract and, where appropriate, my legitimate interests in providing a safe and professionally responsible service.

Where health or other special category information is involved, an additional condition is required. Where appropriate, I will rely on your explicit consent. Other conditions may apply in limited circumstances, for example where information is necessary to establish, exercise or defend legal claims or to protect vital interests in an emergency.

Providing coaching

I use personal information to provide agreed coaching services, manage the coaching relationship and fulfil the Coaching Services Agreement.

The lawful basis will normally be performance of a contract.

Appointments and administration

I use information to arrange sessions, communicate about appointments, manage cancellations and payments, maintain appropriate records and operate the business.

Depending on the particular purpose, the lawful basis may be performance of a contract, compliance with a legal obligation or my legitimate interests in operating and administering the business responsibly.

Professional supervision

Professional supervision is part of safe, reflective and ethical coaching practice.

I may discuss aspects of coaching work in professional supervision. I will minimise identifying information and will use anonymised or appropriately de-identified information wherever reasonably possible.

I will not routinely disclose your identity to a supervisor.

Financial, legal and regulatory responsibilities

I may process information where necessary for:

accounting and taxation
insurance
data protection compliance
professional obligations
complaints
legal claims
responding to lawful requests from regulators or authorities

The lawful basis may be compliance with a legal obligation or my legitimate interests in protecting my business and legal position.

Safety and emergencies

Information may be used where reasonably necessary to protect your safety or the safety of another person.

In an emergency, the lawful basis may include vital interests.

Feedback and service development

I may invite confidential feedback about your experience of coaching.

I may use non-identifying feedback to reflect on and improve my service where this is within my legitimate interests.

I will not publish identifiable feedback or a testimonial without separate permission.

Marketing

Submitting an enquiry or becoming a client does not automatically place you on a marketing mailing list.

If I introduce marketing communications, I will use an appropriate lawful basis and provide a clear way to opt out.

8. Information you need to provide

You can choose whether to make an enquiry or enter into coaching.

However, some information is necessary for me to provide particular services.

For example:

I need sufficient contact information to respond to you
I need enough information to determine what service you are requesting
I may need relevant information to assess whether coaching is appropriate and safe
an emergency contact is required for Outdoor Coaching
payment and invoicing information may be required for paid services
some records must be retained for legal, tax, insurance or professional reasons

You are not required to:

consent to marketing
provide a testimonial
allow your information to be used for research
agree to publication or publicity
disclose health information that is not relevant to the service

If information is genuinely necessary for me to provide a service safely or lawfully, I will explain this.

9. Who I may share information with

I do not sell personal information.

I do not routinely disclose coaching content to other people.

Where reasonably necessary and lawful, information may be shared with:

professional supervisors
technology and cloud-service providers
banking or payment providers
accountants, tax advisers or other professional advisers where required
insurers or insurance brokers where relevant
legal advisers
regulators or public authorities where required by law
emergency services or an emergency contact where necessary for safety
another person where you have specifically asked me to share information with them

Service providers are given access only to information reasonably necessary for the service they provide.

Where a provider processes personal data on my behalf, I will take reasonable steps to use providers with appropriate privacy, confidentiality and security arrangements.

10. Organisation-funded coaching

Where an employer, charity, trust or another organisation pays for coaching, the organisation may be a separate Data Controller for information it collects and uses for its own purposes.

The fact that an organisation funds coaching does not give it unrestricted access to information about the coaching relationship.

Before coaching begins, I will aim to make clear what administrative information, if any, will be shared with the funder.

This might include information such as:

whether coaching has started
the number of sessions used or remaining
attendance where this has been agreed and is necessary
invoicing or payment information
whether the coaching arrangement has concluded

I will not normally disclose what is discussed in coaching, coaching notes, personal reflections or other confidential coaching information to a funder without your permission.

Any exceptions will be limited to circumstances where disclosure is required or otherwise permitted by law, necessary to address a serious safety concern, or expressly agreed with you in advance.

11. Google services and other providers

I use Google Workspace services in operating Coaching with Diana.

These may include:

Gmail for email
Google Calendar for appointments
Google Drive for secure electronic storage
Google Meet for online coaching
Google Forms for enquiries or other forms
Google Sites for the Coaching with Diana website

Online coaching is provided through Google Meet.

I do not routinely record Google Meet coaching sessions.

Google and other service providers may process information in providing their services. Their own privacy and security arrangements may also apply to aspects of that processing.

I may also use reputable providers for:

banking and payments
accounting
invoicing
insurance
website or domain services
information technology support
other services reasonably necessary to operate the business

I review service providers and the type of information they process where appropriate.

12. International processing and transfers

Some technology and service providers may store or process information outside the Isle of Man.

Where personal data is transferred internationally, I will take reasonable steps to ensure that the transfer is lawful and that an appropriate transfer mechanism or safeguard is used where required.

This may include relying on an adequacy arrangement, approved contractual safeguards or another lawful transfer mechanism.

I will consider the nature and sensitivity of the information when selecting and using providers.

13. How I protect personal information

I use reasonable technical and organisational measures designed to protect personal information from accidental loss, inappropriate access, misuse, alteration or disclosure.

Depending on the information and system involved, these measures may include:

password protection
multi-factor authentication where available and appropriate
access controls
secure devices and cloud storage
software and security updates
encryption where available and appropriate
data minimisation
anonymisation or pseudonymisation where appropriate
keeping contact information separate from coaching notes where reasonably practicable
secure storage of any paper records
secure disposal and deletion
reviewing providers and security arrangements
procedures for responding to suspected personal data breaches

No electronic or physical system can guarantee complete security, but I aim to use measures proportionate to the sensitivity of the information I hold.

14. How long I retain information

I retain personal information only for as long as it is reasonably required for the purpose for which it was collected and for any relevant legal, tax, insurance, professional or dispute-resolution requirements.

My normal retention periods are as follows.

Enquiries and introductory conversations

If you make an enquiry but coaching does not proceed, I will normally retain enquiry correspondence and records for up to 12 months after our last meaningful contact.

Pre-coaching suitability and health information

If you provide health or other special category information during the pre-coaching process but coaching does not proceed, I will normally delete it within six months, unless there is a specific legal, safety, complaint or other legitimate reason to retain it longer.

If coaching proceeds, relevant information may become part of the coaching record and be retained in accordance with the coaching-record period below.

Coaching records

Coaching records will normally be retained for six years after the coaching relationship ends.

This may include the agreement, relevant correspondence, brief coaching notes, forms, consent records and other information reasonably forming part of the professional record.

Outdoor coaching emergency contacts

Emergency contact details will be retained only for as long as they are reasonably required for Outdoor Coaching.

They may be retained for longer where they form part of a record concerning an accident, incident, complaint or legal matter.

Financial and tax records

Financial, invoicing and accounting records will normally be retained for at least six years, or longer where required by applicable law.

Testimonials and permissions

A testimonial and the associated permission may be retained for as long as the testimonial is being used, together with a reasonable period afterwards to maintain a record of the permission given or withdrawn.

Marketing information

If you choose to receive marketing communications in future, your details may be retained until you unsubscribe or object.

I may retain a minimal suppression record after an opt-out so that I can respect your preference and avoid contacting you again.

Complaints, safety incidents and legal matters

Information relating to a complaint, safeguarding or safety concern, insurance matter, dispute or legal claim may need to be retained for longer where reasonably necessary.

Retention periods are reviewed and information that is no longer required will be securely deleted, destroyed or anonymised as appropriate.

15. Your data protection rights

Depending on the circumstances and the lawful basis being used, you may have rights to:

be informed about how your personal information is used
request access to personal information I hold about you
ask for inaccurate information to be corrected
ask for incomplete information to be completed
request erasure of personal information
request restriction of processing
object to certain processing
request data portability where applicable
withdraw consent where processing is based on consent
object to direct marketing at any time
complain to the Isle of Man Information Commissioner
challenge decisions based solely on automated processing where the relevant legal conditions apply

These rights are not absolute and particular rights may not apply in every circumstance.

I do not currently use solely automated decision-making or profiling to determine whether someone can receive coaching.

To exercise a data protection right, please contact:

diana@coachingwithdiana.co.uk

I may need to ask for reasonable information to verify your identity before releasing or changing personal data.

I will respond within the period required by applicable data protection law, normally within one month where the Applied GDPR timescale applies.

16. Complaints

If you have a concern about how I have handled your personal information, please contact me first if you feel able to do so.

Email: diana@coachingwithdiana.co.uk

I will take data protection concerns seriously and aim to address them fairly and promptly.

You also have the right to complain to the:

Isle of Man Information Commissioner
P.O. Box 69
Douglas
Isle of Man
IM99 1EQ

Telephone: +44 1624 693260
Email: ask@inforights.im

Where another data protection authority has jurisdiction, you may also have the right to raise a concern with that authority.

17. Information about other people

During an enquiry or coaching relationship, you may talk about other people.

Where possible, please avoid providing unnecessary identifying or sensitive information about another person.

For example, it may often be sufficient to describe someone by their relationship to you rather than provide their full name or contact details.

If you provide an emergency contact for Outdoor Coaching, you should make sure that the person knows that you have provided their details to me and that I may contact them if reasonably necessary in an emergency or serious welfare situation.

18. Academic work, professional development, research and artificial intelligence

I undertake ongoing professional development, supervision and postgraduate study.

I may reflect on themes and learning from my coaching practice for professional development, supervision and improvement of my work.

I will not use identifiable client information for:

academic research
a dissertation
academic assessment
teaching
publication
conference presentations
training materials
public case studies

unless I have obtained separate, specific and informed consent where required.

Agreeing to coaching does not constitute consent to participate in research.

Choosing not to participate in research or academic work will not affect the coaching service you receive.

Information that has been fully anonymised so that an individual can no longer reasonably be identified may be used for legitimate professional learning or development where lawful and ethically appropriate.

Artificial intelligence

I will not enter identifiable client information, confidential coaching content or coaching notes into a public or general-purpose generative artificial intelligence system.

If I consider using an artificial intelligence or automated service that would process client personal data in future, I will first consider necessity, proportionality, confidentiality, security, provider terms, international transfers and applicable data protection requirements.

I will update this Privacy Notice and obtain additional information or consent where required before introducing such processing.

19. Children

Coaching with Diana provides coaching services to adults aged 18 or over.

I do not knowingly collect children's personal information through the website for the purpose of providing coaching.

If I become aware that a child has provided personal information in circumstances where I have no lawful reason to retain it, I will delete it as appropriate.

20. Cookies

The Coaching with Diana website may use cookies or similar technologies that are necessary for the website and embedded services to function.

Because the website and enquiry form use Google services, Google may also use cookies or process technical information in connection with delivering, securing and operating those services.

I do not intend to use unnecessary tracking, advertising or behavioural-marketing technologies without providing appropriate information and choices where required.

If I introduce analytics or other non-essential technologies in future, I will review the privacy and cookie requirements and update the website and this notice as necessary.

You can control cookies through your browser settings, although disabling some cookies may affect how websites or embedded services function.

21. Links to other websites

The Coaching with Diana website may contain links to websites operated by other organisations.

I am not responsible for the content, security or privacy practices of external websites.

If you follow a link to another website, you should review that organisation's own privacy information where appropriate.

22. Personal data breaches

If I become aware of a suspected personal data breach, I will take reasonable steps to:

contain and investigate it
assess the nature of the information involved
consider the likely consequences for affected individuals
document the incident as required
take appropriate remedial action
notify the Isle of Man Information Commissioner where required by law
inform affected individuals where legally required

If you believe that personal or confidential information connected with Coaching with Diana has been sent to the wrong person, lost, accessed without permission or otherwise compromised, please contact me as soon as possible at:

diana@coachingwithdiana.co.uk

23. Changes to this notice

I may update this Privacy Notice from time to time to reflect changes to:

my services
technology
service providers
professional practice
data protection requirements
legal or regulatory guidance

The most recent version will be published on the Coaching with Diana website with the date of the latest update.

Where a significant change materially affects existing clients or how their personal information is used, I will take reasonable steps to bring the change to their attention.

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