Privacy Policy

This Privacy Policy explains how TurnComms Ltd, trading as Turner Coaching ('we', 'us', 'our') collects, uses, and protects your personal data. We are the data controller.

Registered address

[Registered Address]

ICO Registration Number

[ICO Registration Number]

Contact for data matters

coaching@turncomms.com

2.1 Data you provide to us

• Name and contact details (email address, phone number)
• Booking information (session type, date, time)
• Payment information (processed by our payment provider — we do not store card details)
• Information you share during coaching sessions, including notes we take
• Session recordings, where you have provided consent
• Communications with us by email or other means

2.2 Data collected automatically

• Website usage data via cookies (see our Cookie Policy)
• Scheduling data collected through our booking platform

2.3 Special category data

Some information you share with us — including details about your mental health, emotional wellbeing, relationship history, and any disclosures made during or in connection with coaching sessions — constitutes special category personal data under Article 9 of the UK GDPR. We collect and process this data only with your explicit consent, which you provide when completing the Client Intake Questionnaire before your first session. You may withdraw this consent at any time by contacting coaching@turncomms.com, though this may affect our ability to provide coaching services to you.

We use your personal data for the following purposes:

3.1 To provide coaching services

Legal basis: Performance of a contract with you.

Legal basis (special category data): Explicit consent under Article 9(2)(a) UK GDPR, collected via the Client Intake Questionnaire.

• To deliver booked sessions and manage your appointments
• To maintain session notes to support continuity of coaching
• To store session recordings (where consent given)

3.2 To manage our business relationship

Legal basis: Performance of a contract / Legitimate interests.

• To process payments and issue receipts
• To respond to your enquiries
• To send booking confirmations and reminders

3.3 To comply with legal obligations

Legal basis: Legal obligation.

• To maintain records as required by law
• To respond to lawful requests from authorities

We do not use your personal data for marketing purposes without your explicit consent. We do not sell your data to any third party.

We use the following third-party tools to deliver and administer our services. Each is operated under a Data Processing Agreement (DPA):

4.1 Google Workspace (Google LLC, USA)

Used for email, video calls (Google Meet), and secure document and notes storage. Google LLC is based in the USA; data transfers are covered by the UK International Data Transfer Agreement (IDTA) and Standard Contractual Clauses. TurnComms Ltd holds a Google Workspace for Business subscription with a DPA in place.

4.2 Scheduling Platform

Used for appointment booking. Current platform: [Cal.com / confirmed platform name]. A DPA is in place with this provider. Server location: [EU / UK].

4.3 Payment Processing

Payments are processed by [Payment Provider]. We do not store your payment card details.

If we change any of the tools listed above, we will notify you in writing no less than 30 days before the change takes effect. Any replacement tool will be subject to equivalent data protection standards.

1. 5.1We will only record a session with your express prior consent. Consent will be sought before the start of any recorded session.
2. 5.2Recordings are stored securely on Google Workspace (Google Drive), covered by the DPA referenced in section 4.1.
3. 5.3Recordings are retained for [X months/years] from the date of the session, after which they are permanently deleted. You may request earlier deletion at any time.
4. 5.4Recordings are not shared with any third party except as required by law.

If you choose to book a session by email rather than through our online booking system, your name and contact details will be held in our Google Workspace email account. This data is subject to the same security standards as all other personal data we hold. It will be used solely to confirm and manage your booking.

We retain your personal data only for as long as necessary for the purposes set out in this policy, or as required by law. Our standard retention periods are:

• Session notes: [X years] from the date of your last session
• Risk, referral, and safeguarding records: 7 years from the date of the last session (professional practice standard for sensitive disclosures)
• Session recordings: [X months] from the date of the session
• Booking and payment records: 6 years (HMRC requirement)
• Email correspondence: [X years] from the date of last contact

At the end of the applicable retention period, data is permanently deleted.

Under UK data protection law, you have the following rights:

• Right of access — to request a copy of the personal data we hold about you
• Right to rectification — to ask us to correct inaccurate data
• Right to erasure — to ask us to delete your data (subject to legal retention requirements)
• Right to restrict processing — to ask us to limit how we use your data
• Right to data portability — to receive your data in a structured, machine-readable format
• Right to object — to object to processing based on legitimate interests
• Rights related to automated decision-making — we do not use automated decision-making or profiling

To exercise any of these rights, contact us at coaching@turncomms.com. We will respond within one calendar month.

We take appropriate technical and organisational measures to protect your personal data, including:

• Use of Google Workspace, secured with two-factor authentication
• Access to client data restricted to Nicole Turner only
• Devices used to access client data are password-protected and encrypted
• Session recordings are stored in a restricted access folder

If you have concerns about how we handle your personal data, please contact us in the first instance at coaching@turncomms.com. If you remain unsatisfied, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

ICO helpline

0303 123 1113

ICO website

ico.org.uk

We may update this Privacy Policy from time to time. We will notify you of any material changes by email and will update the 'Last updated' date above. We encourage you to review this policy periodically.