Draft for review. Items shown in a dashed amber box still need confirming. See README-FIRST.md in this folder.

Legal

Privacy Notice

How The AML Co. collects, uses, stores and protects personal information — for adults coming to coaching themselves, and for parents and carers arranging Children’s Coach.

Draft, based on Alice’s own Children’s Coach Privacy Notice V1 and extended to cover adult coaching. Three items below still need confirming before publication.

1. About this notice


This notice explains how The AML Co. handles personal information when providing coaching and when communicating with clients, parents and carers.

The AML Co. is a small, independent practice. Alice is responsible for deciding how personal information is used and for keeping it appropriately secure.

It is written primarily for adults — clients, parents and carers. Children are also entitled to clear, age-appropriate information about how their information is used, and this is explained to them directly in a way suited to their age and understanding.

2. What information is collected


For adult coaching:

  • Name and contact details
  • What you have said about why you are coming to coaching and what you hope to get from it
  • Brief session notes and agreed actions
  • Booking and payment records

For Children’s Coach:

  • Parent or carer name and contact details
  • The child’s name, age and relevant contact or emergency information
  • Information a parent or carer provides about the child’s circumstances, strengths, needs, interests or goals for coaching
  • Information the child chooses to share during coaching
  • Brief coaching notes, session records and agreed actions
  • Consent and booking information, and payment records
  • Information needed to manage a safeguarding concern or make an appropriate referral
  • Practical information needed to arrange sessions, including whether they are in person or online

Only information that is relevant and necessary is collected. Full medical histories, school records and diagnostic reports are not asked for unless there is a clear reason they are needed.

3. Where information comes from


Directly from you, directly from the child during coaching, or through communication with another person where that is appropriate and lawful. Information provided by someone else is handled under this notice in the same way.

4. Why information is used


  • To respond to enquiries and arrange coaching
  • To provide and manage sessions, and understand the context the coaching sits in
  • To keep appropriate records of the work and the agreed next steps
  • To communicate about practical matters and, where appropriate, about a child’s coaching
  • To process payments and keep financial records
  • To manage safeguarding concerns and meet legal or professional responsibilities
  • To consider whether coaching remains appropriate and, where needed, signpost or refer elsewhere
  • To meet legal, regulatory and insurance requirements where they apply

Information is never used for advertising or unrelated marketing.

5. Lawful bases


Personal information is used only where there is a lawful basis. Depending on the purpose, that may be:

  • Taking steps at your request before entering into an agreement, and providing the service
  • Performing the agreement for the coaching service
  • Complying with a legal obligation
  • Protecting someone’s vital interests in an emergency
  • Legitimate interests in running and administering the practice, where those are not overridden by an individual’s rights

Where consent is the appropriate basis for a particular use, it is asked for separately and what it is for is explained.

6. Children’s information, and sensitive information


Children’s information is handled with particular care.

Parents and carers may provide information about a child’s wellbeing, circumstances or support needs where it is relevant. Some of this may be special category data under data protection law. It is collected or used only where relevant and where there is an appropriate lawful basis and any additional condition the law requires.

The aim is always the minimum needed to provide safe and appropriate coaching.

7. Confidentiality and safeguarding


Coaching conversations are treated respectfully and with appropriate confidentiality.

Parents and carers provide important context, but coaching is meant to give the child space to think and find their own focus. Detailed session conversations are not routinely shared with parents.

There are important limits. Where there is concern that a child or another person may be at risk of harm, information may need to be shared with a parent or carer, a safeguarding professional, a statutory service or another appropriate person — including without permission where that is necessary to protect someone.

Safeguarding information is handled under the practice’s separate Safeguarding Policy and concern-recording arrangements, and is kept separately from ordinary session notes.

8. Who information may be shared with


Information is shared only where there is a genuine reason and the sharing is lawful and appropriate. That may include:

  • A parent or carer, where appropriate
  • Safeguarding professionals or statutory services, where necessary
  • Another professional or service, where a referral or signposting is appropriate
  • Service providers who help run the practice — payment, booking, email, online meeting or secure storage
  • An insurer, accountant or professional adviser, where necessary
  • Public authorities, where the law requires it

Personal information is never sold, and children’s information is never shared for unrelated marketing.

To confirm before publishing

The actual booking, payment, email, video and storage providers in use, and whether any of them process information outside the UK. Alice’s own Privacy Notice V1 and her Data Protection Pack both list this as a pre-launch check.

9. Online sessions and digital services


Where coaching is delivered online, third-party services may be used for video meetings, communication, booking, payment or secure storage. Appropriate settings and practices are used to protect information. Those providers process information under their own privacy policies and may process it outside the UK; where that applies, the steps required by data protection law are taken.

Online coaching is subject to the same boundaries, confidentiality and safeguarding expectations as in-person coaching.

10. How information is kept secure


Reasonable technical and organisational steps are taken to protect personal information against loss, misuse, unauthorised access, alteration or disclosure — passwords and access controls, records kept in secure systems, access limited to what is necessary, and care taken over how information is sent and stored.

No method of storing or sending information can be guaranteed completely secure, but proportionate steps are taken to protect what is held.

11. How long information is kept


Personal information is not kept longer than is reasonably necessary for the purpose it was collected for, taking account of legal, safeguarding, insurance, financial and record-keeping requirements. Different types of record are distinguished where appropriate, and information is securely deleted or destroyed when no longer needed.

Where a safeguarding concern or another matter requires information to be kept longer, it may be retained for as long as is reasonably necessary to meet that responsibility.

To confirm before publishing

The specific retention periods for client records, safeguarding records, financial records and correspondence. Deliberately left open — Alice’s Data Protection Pack ยง15 says in terms: do not insert a guessed retention period.

12. Your rights


Depending on the circumstances you may have the right to ask for access to the information held about you, to have inaccurate information corrected, to have information erased, to have processing restricted, to object to certain processing, and to have information transferred. Where processing is based on consent, you can withdraw it — which does not affect processing that already took place.

Children can exercise their own rights depending on their age, understanding and capacity, and are supported to do so. These rights are subject to legal conditions and exemptions, so they do not apply in every situation.

13. Making a request, or raising a concern


Contact Alice at alice@theamlco.co.uk. Requests are handled in line with data protection requirements and are recorded rather than answered informally.

You also have the right to complain to the Information Commissioner’s Office, the UK regulator, at ico.org.uk.

14. Keeping this notice up to date


This notice is reviewed regularly and updated if the way information is collected, used or stored changes, or if data protection requirements change. The most recent version is provided as part of the information and consent process.

Add the publication date here.