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Privacy Policy

Last updated: 11 November 2026

 

This policy explains what personal information Torchwood Coaching collects, why we collect it, and what your rights are. It applies to visitors to torchwoodcoaching.com, people who get in touch with us, coaching clients and professional contacts.

 

1. Who we are

 

Torchwood Coaching Ltd is the “controller” of your personal information. We are a private limited company registered in England and Wales (company number 15146857). Our registered office is 23 Thornton Street, St Albans, AL3 5JW.

 

Laurence Hewitt, Director, is responsible for data protection. You can reach him at hewitt@torchwoodcoaching.com or by post at the address above. We are not required to appoint a data protection officer.

 

We follow the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and, where it applies to people in the European Economic Area, the EU GDPR.

 

If you are coached by Laurence through your employer’s programme or a coaching platform, that organisation is usually responsible for your information, and its own privacy notice applies as well.

 

2. What we collect, and where it comes from

 

Information you give us

 

  • Enquiries: your name, email address, phone number (optional) and your message.

  • Bookings: the details you enter when you book a session.

  • Coaching: your goals, our session notes, anything you choose to tell us, and the results of any assessments you agree to take.

  • Billing: the details we need to invoice you and record your payment.

  • Mailing list: your email address.

 

Sensitive information. In coaching you may choose to tell us about your health or other sensitive matters. We record this only where it helps our work together, and only with your explicit consent.

 

Recordings. With your agreement, sessions may be recorded and transcribed so that accurate notes can be kept.

 

Information we receive from others

 

  • Your employer or sponsor, if they arrange your coaching: your name, role, work contact details and the aims of the programme.

  • People you nominate to give feedback, for example in a 360-degree review: their views about you, and their own name and work email address.

  • Assessment providers: your results.

  • LinkedIn and professional contact directories: the name, job title, employer and work contact details of people we think may be interested in our services.

 

Information collected automatically. If you agree to analytics cookies, we collect information about how the site is used (see section 10).

 

3. How we use your information, and our lawful basis

 

  • Reply to your enquiry and arrange an introductory call: Legitimate interests (responding to people who contact us), or steps you ask us to take before entering a contract

  • Provide coaching, keep session notes, schedule sessions and invoice you: Contract

  • Record sensitive information you choose to share in coaching: Explicit consent

  • Record and transcribe sessions: Consent

  • Send you our newsletter or updates: Consent

  • Contact professionals who may be interested in our services: Legitimate interests (growing our business). You can opt out at any time

  • Share general, anonymised themes from our coaching work, for example in articles and posts. These never identify you or your organisation: Legitimate interests (sharing what we learn)

  • Measure how the website is used: Consent, given through the cookie banner

  • Keep the website secure and working: Legitimate interests (running a safe, reliable site)

  • Keep accounting and tax records, and respond to lawful requests: Legal obligation

  • Handle complaints and legal claims: Legitimate interests (protecting our business and our clients)

 

We do not make decisions about you by automated means, and we do not carry out profiling. Where we use AI tools, for example to transcribe or summarise a session, Laurence reviews what they produce.

 

4. Do you have to give us your information?

 

No law requires you to. But we need your name and contact details to reply to you, and coaching clients must provide the details needed for our coaching agreement and invoices. What you share in sessions is always your choice.

 

5. Who we share it with

 

We never sell your information. We share it only with:

 

  • Service providers who work on our instructions: our website, forms and mailing list provider (Wix); website analytics (Google); scheduling and video calls (Zoom); email, calendar and document storage; AI note-taking and productivity tools; assessment providers; accounting software and our accountants.

  • Your employer or sponsor, where they fund your coaching: only what you, they and we agreed at the start. We do not share what you say in sessions.

  • Professional advisers and insurers, if we need their help.

  • Regulators, courts or the police, where the law requires it.

 

Coaching conversations are confidential. The limited exceptions, such as a serious risk of harm, are set out in your coaching agreement.

 

6. Sending information outside the UK

 

Some of our providers are based in, or store information in, other countries, including the United States. When your information leaves the UK it is protected either by UK “adequacy” regulations or by contract terms recognised under UK data protection law. Contact us if you would like more detail about the safeguards for a particular provider.

 

7. How long we keep it

 

  • Enquiries that don’t lead to coaching: 12 months after our last contact

  • Coaching records and session notes: 6 years after your coaching ends

  • Session recordings and transcripts: Up to 12 months after your coaching ends, or sooner if you ask

  • Invoices and accounting records: 6 years from the end of the financial year, as the law requires

  • Mailing list: Until you unsubscribe

  • Professional contacts: Until you ask us to stop, or 2 years after our last contact

  • Website analytics: Up to 14 months

 

After that we delete the information securely or anonymise it.

 

8. Your rights

 

You have the right to:

 

  • be told how we use your information (which is what this policy does);

  • ask for a copy of the information we hold about you;

  • ask us to correct anything that is wrong or incomplete;

  • ask us to delete your information;

  • ask us to limit how we use it;

  • object to our using it where we rely on legitimate interests, and to direct marketing at any time;

  • receive the information you gave us in a portable format, where we use it under consent or contract;

  • withdraw your consent at any time. This does not affect anything we did before you withdrew it.

 

To use any of these rights, email hewitt@torchwoodcoaching.com. It is free, and we will reply within one month. We may need to check your identity first.

 

9. Complaints

 

If you are unhappy with how we have handled your information, please tell us first by emailing hewitt@torchwoodcoaching.com. We will acknowledge your complaint within 30 days, look into it, and tell you the outcome without undue delay.

 

You can also complain to the UK regulator, the Information Commission (ICO), at ico.org.uk/make-a-complaint. If you live in the European Economic Area, you can complain to your local data protection authority.

 

10. Cookies

 

Cookies are small files stored on your device.

 

  • Essential cookies are needed for the site to work and stay secure. They are set by our website provider, Wix, and do not need your consent.

  • Analytics cookies (Google Analytics and Wix) help us understand how the site is used. They are only set if you accept them in the cookie banner.

 

You can change or withdraw your choice at any time using the cookie settings on the site, or through your browser settings. Our booking page is hosted by Zoom, which uses its own cookies and has its own privacy notice.

 

11. Keeping your information secure

 

We take appropriate technical and organisational measures to protect your information, including limiting who has access to it and using reputable, secure providers. If a data breach is likely to put you at serious risk, we will tell you promptly.

 

12. Children

 

Our services are for adults. We do not knowingly collect information from anyone under 18.

 

13. Changes to this policy

 

When we change this policy we will update this page and the date at the top. If a change is significant, we will tell current clients directly.

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