Privacy Notice — Modus Coaching
Last updated: 8 November 2026
Modus Coaching takes the privacy and confidentiality of its clients seriously. This notice explains what personal information we use, why we use it, who may receive it and what choices and rights you have.
1. Who is responsible for your information?
Modus Coaching is a trading name of GBC Limited, registered in England and Wales under company number 16963900. We act as the data controller for personal information processed for our own coaching services and business administration.
Registered office: 50B Cambridge Road, New Malden, England, KT3 3QL
Privacy contact: moduscoaching.info@gmail.com
If an employer or another organisation arranges or pays for coaching, it may be a separate controller for its own personnel and purchasing records. Paying for coaching does not give it automatic access to private coaching content.
2. What information do we use?
Depending on how you interact with us, we may process:
- Your name, email address, telephone number and organisation, where provided.
- Enquiries, correspondence, bookings, attendance and information needed to arrange your coaching.
- The agreed service, contract, invoices, payment status and relevant bank-transfer references.
- Goals or reflections you choose to discuss and brief handwritten coaching notes relevant to our work together.
- Sensitive information, such as details about health, disability or neurodivergence, where voluntarily disclosed and lawfully processed for coaching.
- Limited technical information needed to serve and secure our website, which may include IP address, device/browser details, timestamps and requested pages.
We use identifying numbers instead of client names on handwritten coaching notes. Because we can connect a reference number to a client, these notes are pseudonymised personal data, not fully anonymous data.
We do not record or transcribe coaching sessions. We do not use an online contact form or online card checkout on the current website.
3. Why we use information and our lawful bases
Under the UK GDPR, we use information only when there is an appropriate lawful basis:
| Purpose | Lawful basis |
|---|---|
| Responding to personal enquiries and arranging individual coaching | Steps before entering into a contract, or performance of a contract |
| Providing coaching to an individual client | Performance of a contract; where relevant, legitimate interests for limited supporting administration and working notes |
| Arranging employer-funded coaching and contacting business representatives | Legitimate interests in managing the service and business relationship |
| Invoices, accounting and statutory records | Legal obligation; contract where applicable |
| Responding to complaints or protecting legal rights | Legitimate interests and, where applicable, legal obligation |
| Maintaining website functionality and security | Legitimate interests in operating and protecting the website |
Where we rely on legitimate interests, we consider the interests and rights of the people affected. We do not sell client information or use coaching information for advertising.
Sensitive information
Coaching may involve special-category data, such as health or disability information. Where we need to process such information, we also require a separate condition under Article 9 of the UK GDPR. Where appropriate, we rely on explicit consent, sought separately and documented before that processing takes place. Consent can be withdrawn; withdrawal does not invalidate processing already carried out lawfully. If another lawful Article 9 condition applies in a particular situation, we will use it only where its requirements are met.
Clients are not required to disclose a diagnosis simply to ask about coaching. Please avoid sending unnecessary medical or sensitive information in an initial email.
4. Confidentiality and organisation-funded coaching
Private coaching discussions and notes are confidential, except where a limited disclosure is lawful and necessary, for example with informed permission, where required by law, to provide the service, or where justified to address a serious risk of harm or legal claims.
If an organisation pays for coaching, it does not automatically receive the participant's personal coaching notes or confidential session content. Any administrative or progress information to be shared will be explained and agreed in advance. We do not share confidential or sensitive information merely because an organisation pays for the sessions.
5. How we keep information secure
We use appropriate organisational and technical safeguards to protect the information we handle. Handwritten coaching notes are identified by reference number and kept in secure storage, separate from routine financial and administrative records. Access is restricted to the coach.
We use reasonable safeguards for our email and online communications. No method of electronic communication can be guaranteed completely secure. If a personal-data incident occurs, we will assess and report it as required by applicable law.
6. How long we keep information
- Handwritten coaching notes: retained only while the coaching relationship is active, then securely destroyed when it ends, unless a specific legal preservation obligation applies.
- Email correspondence, contact and booking information: kept only while needed to communicate, provide services and deal with reasonable administrative or legal matters. We will assess and action deletion requests in accordance with applicable law and delete information that is no longer needed. Some correspondence may need to be retained to meet legal obligations or establish, exercise or defend legal claims.
- Contracts, invoices, bank-transfer and accounting records: retained for the periods required by applicable law. Relevant UK company tax records are generally kept for at least six years from the end of the financial year concerned, and longer where required.
- Website technical records: may be kept for limited periods by our hosting provider according to its operational and security requirements.
We do not retain recordings or transcripts because we do not create them.
7. Who we share information with
When necessary for the service or lawful business administration, personal information may be handled by:
- Google for our Gmail business email and Google Meet sessions.
- WhatsApp for coaching communications or calls when that platform is chosen.
- Cloudflare for website hosting, delivery and security.
- Our bank for direct bank-transfer payments.
- Professional advisers or relevant public authorities where legally justified.
- An organisation purchasing coaching, but only to the limited extent lawfully agreed and explained under section 4.
These providers process information under their own applicable terms and privacy arrangements. We do not sell personal data or give third parties permission to use private coaching content for their marketing.
8. International processing
Google, WhatsApp and Cloudflare may process some information outside the UK. Where UK data-protection rules restrict a transfer, we rely on appropriate legal safeguards such as an applicable adequacy decision or recognised contractual protections. We do not claim that all electronic communications remain physically within the UK.
9. Website operation and tracking
Our website is a static information site. We do not use it to collect contact-form submissions, process online card payments or carry out advertising-based behavioural tracking. Cloudflare processes technical requests as needed to deliver and protect the site.
We do not intentionally install non-essential advertising or analytics cookies. If we add optional visitor analytics or other tracking technologies in the future, we will update this notice and provide any legally required information or choices before using them.
Links to other sites, and calls or messages made using Google Meet or WhatsApp, are also subject to the relevant third-party providers' privacy practices.
10. Your rights
Subject to applicable legal conditions and exceptions, you may have rights to:
- Access personal information we hold about you.
- Correct inaccurate information.
- Ask for erasure or restriction of processing.
- Object to processing in relevant circumstances.
- Receive or transfer eligible information in a portable format.
- Withdraw consent where we rely on consent.
- Complain about how your information is handled.
Email moduscoaching.info@gmail.com to make a request. We may need to verify your identity before sharing information. We will respond within the legal timeframes. Deletion is not absolute: information may need to be retained to comply with law or establish, exercise or defend legal claims.
11. Complaints
For a concern or complaint about personal information, email moduscoaching.info@gmail.com. We will acknowledge a data-protection complaint within 30 days, investigate it appropriately and communicate the outcome without undue delay.
You may also complain to the Information Commissioner's Office (ICO) at https://ico.org.uk/make-a-complaint/. You do not have to contact us first in order to exercise your regulatory rights.
12. Your choices and changes to this notice
We need some basic information to respond to an enquiry, agree coaching, issue invoices and satisfy legal obligations. Other personal information shared during coaching is generally voluntary, although an absence of relevant information may affect what support we can appropriately provide.
We do not use solely automated decision-making that has legal or similarly significant effects on clients.
We may update this notice when our services or legal requirements change. The revision date at the top will show when it was last updated; material changes will be communicated where required.
Business details: GBC Limited, trading as Modus Coaching. Registered in England and Wales, company number 16963900. Registered office: 50B Cambridge Road, New Malden, England, KT3 3QL. Email: moduscoaching.info@gmail.com.