Privacy Notice
Sapien Coaching
Last updated: 11 October 2026
1. Who we are
Sapien Coaching is the trading name of Sapien Coaching & Development Ltd, a company registered in England and Wales.
Company registration number: 11871034
Registered office:
197–201 Manchester Road
West Timperley
Altrincham
Cheshire
WA14 5NU
Sapien Coaching & Development Ltd is the data controller responsible for the personal information collected and processed in connection with our website and coaching services.
For questions about this notice, or to exercise your data protection rights, please contact:
steve.neary@sapiencoaching.com
2. Personal information we collect
We collect and process personal information where necessary to operate our business and provide coaching services.
This may include:
Website enquiries
- Name and email address.
- Organisation, where provided.
- Information included in messages submitted through our website or sent directly by email.
Coaching clients
- Contact details, organisation and professional role.
- Coaching objectives and development priorities.
- Information shared during coaching discussions where relevant to the coaching relationship.
- Agreed actions, progress and outcomes.
- Coaching agreements and session arrangements.
Coaching reflection notes
We may prepare written reflection notes following coaching sessions. These focus primarily on leadership, behaviour, professional development, objectives, insights and agreed actions.
Clients may occasionally share personal or sensitive information during coaching conversations. We aim to minimise the recording of such information and avoid retaining unnecessary details about personal circumstances or health.
Business administration
- Contracts, correspondence, invoices and payment records.
- Information required to manage our business and comply with legal obligations.
Hogan assessments
Where agreed as part of coaching, we use Hogan personality assessments supplied through Advanced People Strategies Ltd. We may process assessment administration details, results and reports to support development and feedback. We send the client’s name and email address to Advanced People Strategies Ltd with the client’s permission to arrange the assessment. APS supplies the resulting reports to us for coaching and feedback. The assessment provider’s own privacy information applies to its processing of assessment data.
Website information
Our website processes technical information such as IP addresses, browser and device information and website usage data. Essential cookies support website operation. Optional analytics cookies are restricted until you accept them through the cookie banner.
3. How we use personal information
We use personal information to:
Respond to enquiries and communicate with prospective clients.
Discuss, arrange and deliver coaching services.
Agree and review coaching objectives.
Maintain confidential reflection notes to support continuity and effectiveness.
Manage coaching agreements, appointments and business correspondence.
Issue invoices, administer payments and maintain financial records.
Operate and protect our website and business systems.
Comply with applicable legal and regulatory obligations.
We do not sell personal information. We do not currently send marketing emails or newsletters. We do not record coaching sessions, use transcription services or use AI to process client information.
4. Lawful bases for processing
We process personal information under the UK General Data Protection Regulation (UK GDPR) using the following lawful bases, as appropriate:
Legitimate interests
To respond to business enquiries, maintain professional relationships, keep proportionate coaching records, manage our business and protect our systems, where those interests are not overridden by individuals' rights and freedoms.
Contract
Where processing is necessary to enter into or fulfil a coaching agreement with an individual.
Legal obligation
Where processing is necessary to comply with applicable legal requirements, including financial record-keeping.
Where an organisation sponsors coaching, we rely on legitimate interests to arrange and deliver coaching and maintain proportionate development records for the individual. These interests are supporting the client's professional development and delivering the agreed coaching service, balanced against the individual's rights and confidentiality expectations.
We do not routinely seek to collect special category personal data, such as information about an individual's health.
Where such information is necessary to record or otherwise process, we will identify an appropriate lawful basis under Article 6 UK GDPR and an additional condition under Article 9 before doing so.
Health information is excluded from our written coaching records. We do not routinely retain other special category information. If processing such information becomes necessary, we will explain the purpose and applicable legal condition to the client before doing so, obtaining explicit consent where that is the appropriate condition. Clients should avoid including health or other sensitive personal details in website enquiries.
5. Confidentiality and coaching records
Confidentiality is fundamental to our coaching relationships.
We may maintain written reflection notes following coaching sessions to support continuity, reflection and development.
These notes focus primarily on leadership, behaviour, objectives, insights and agreed actions.
Coaching notes are stored as Word documents within Sapien Coaching's dedicated Microsoft 365 environment, using Microsoft OneDrive.
Access to coaching records is restricted, and we take reasonable measures to protect their confidentiality.
Organisational sponsorship
Where coaching is sponsored by an organisation, objectives and expectations may be agreed directly between the coach and client or through a three-way conversation involving an organisational sponsor.
The content of individual coaching sessions and the coach's reflection notes are not routinely shared with sponsoring organisations.
Any arrangements for sharing progress, objectives or coaching outcomes will be agreed with the client in advance.
Professional supervision
Coaching matters may be discussed as part of professional supervision and development. Information will be anonymised wherever practicable, and confidentiality will be maintained subject to applicable legal and professional obligations.
Confidentiality is not absolute. Information may be disclosed where required by law or where another lawful justification applies.
6. Who we share information with
We may use trusted third-party providers to support our business operations, including:
Squarespace
For website hosting, contact forms and website analytics. Enquiries are delivered to our Sapien Microsoft 365 email account. Our contact form has a required email field, which also causes Squarespace to retain form submitters and submissions in its Contacts panel.
Microsoft
For business email, document creation, communication and secure storage through Microsoft 365 and OneDrive.
Advanced People Strategies Ltd
With the client’s permission, we share their name and email address with APS to arrange an agreed Hogan assessment. APS provides the resulting reports to us for coaching and feedback.
Professional supervision
Coaching matters may be discussed with a professional supervisor, with information anonymised wherever practicable. Where a person could still be identified, we continue to treat the information as personal data and apply confidentiality and data protection requirements.
Banking, accounting and professional services
Where necessary to administer payments, maintain financial records, obtain professional advice or comply with legal obligations.
Where service providers process personal information on our behalf, we seek to ensure appropriate contractual and security arrangements are in place.
We do not sell personal information or provide coaching records to third parties for marketing purposes.
7. International transfers
Some of our technology providers may process or store personal information outside the United Kingdom.
Squarespace’s data-processing terms provide for transfers to the United States under the UK Extension to the EU–US Data Privacy Framework where applicable, and standard contractual clauses with the UK Addendum where required. Microsoft 365 processing is governed by Microsoft’s applicable data-processing terms, which include international-transfer protections. These arrangements do not mean that all data is processed exclusively in the UK.
You can contact us for information about applicable transfer safeguards and how to obtain a copy.
For Hogan assessments, APS and the relevant assessment service provide their own information about where assessment data is processed and any applicable international-transfer arrangements. Our two-year retention period applies to the report copies we hold, rather than records retained by the assessment provider.
8. How long we keep information
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, taking account of relevant legal, contractual and professional requirements.
Our normal retention periods are:
Website enquiries
Enquiries that do not result in a coaching engagement are normally retained for up to 12 months after the last meaningful contact. This applies to the copies we control in Microsoft 365 and Squarespace, including associated contact records where no other retention purpose applies.
Coaching reflection notes
Confidential coaching reflection notes are normally retained for up to two years after the end of a coaching engagement.
This allows us to maintain continuity where clients return for further coaching.
After this period, notes are securely deleted unless there is a specific legal or other lawful reason to retain them for longer.
Our copies of Hogan assessment reports
Normally retained for up to two years after the coaching engagement ends. The assessment provider’s own retention arrangements are explained in its assessment-specific privacy information.
Coaching agreements and business correspondence
Relevant contractual and business records may be retained for up to six years after the engagement ends, where justified by contractual, legal or legitimate business requirements.
Financial records
Financial and accounting records are retained in accordance with applicable legal and tax requirements, generally for at least six years where required.
Where information is no longer needed, we take appropriate steps to delete or securely dispose of it.
Retention periods may be extended where necessary to establish, exercise or defend legal claims or meet other legal obligations.
9. How we protect personal information
We take reasonable technical and organisational measures to protect personal information against unauthorised access, accidental loss, misuse or disclosure.
These include:
Using dedicated business accounts and systems.
Restricting access to confidential coaching information.
Using Microsoft 365 for business communications and document storage.
Maintaining appropriate account and access security.
Limiting the personal information we collect and retain.
Although we take appropriate precautions, no electronic storage or communication system can be guaranteed to be completely secure.
10. Cookies and website analytics
Our website is hosted by Squarespace.
We use Google reCAPTCHA to protect our contact form from spam and abuse. It processes technical information about your device and interaction with the website for security checks and may use cookies or similar technologies.
Essential cookies and similar technologies support website operation and security. Optional Squarespace analytics cookies help us understand how visitors use the website. They are restricted until you accept them through the cookie banner.
The banner provides Accept all, Decline all and Manage cookies options. You can change your choice at any time using Cookie Preferences. Declining optional cookies does not prevent you from making an enquiry.
The visitor activity log is switched off. We have not configured Google Analytics through Squarespace's built-in integration. Where optional analytics involve personal information, we rely on consent for that processing.
Information about Squarespace’s cookies, their purposes and durations is available at https://support.squarespace.com/hc/en-us/articles/360001264507-The-cookies-Squarespace-uses. Cookie Preferences shows the available categories and lets you update your choice.
11. Your data protection rights
Under UK data protection law, you may have the right to:
Request access to personal information we hold about you.
Request correction of inaccurate or incomplete information.
Request deletion of personal information in certain circumstances.
Request restriction of certain processing.
Object to processing based on legitimate interests.
Request transfer of personal information where applicable.
Withdraw consent where consent is the lawful basis for processing.
These rights are subject to applicable legal conditions and exemptions.
To exercise your rights, please contact:
steve.neary@sapiencoaching.com
We will respond in accordance with applicable data protection requirements. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.
Providing contact information is necessary for us to respond to an enquiry. Information required for a coaching agreement or assessment will be explained when the service is arranged. If necessary information is not provided, we may be unable to provide that service.
We do not make solely automated decisions that have legal or similarly significant effects on clients. Where Hogan assessments produce computer-generated reports, these support discussion and professional judgement rather than making such decisions.
You also have the right to raise a complaint with the Information Commissioner's Office (ICO):
Website: https://ico.org.uk
We would welcome the opportunity to address any concerns directly before you contact the ICO.
12. Changes to this notice
We may update this privacy notice to reflect changes to our services, business practices or legal requirements.
The latest version will be available on our website, with the date of the most recent update shown above.
Sapien Coaching & Development Ltd
Trading as Sapien Coaching
Company registration number: 11871034
Registered office:
197–201 Manchester Road
West Timperley
Altrincham
Cheshire
WA14 5NU