Privacy
Policy

Version 5.2 · Effective October 2026 · England & Wales

1.Introduction

The Speech Coach Limited (“The Speech Coach”, “we”, “us”, “our”) is committed to the highest standards of confidentiality, privacy, data protection, safeguarding, professional integrity, and information security.

This policy explains how personal data, recordings, communications, intellectual property, and confidential information are collected, processed, retained, protected, and managed in accordance with:

• the UK General Data Protection Regulation (“UK GDPR”);
• the Data Protection Act 2018 (“DPA 2018”), as amended by the Data (Use and Access) Act 2025;
• the Privacy and Electronic Communications (EC Directive) Regulations 2003 (“PECR”);
• applicable safeguarding obligations under the Children Act 1989, the Children Act 2004, Working Together to Safeguard Children 2023, and associated statutory guidance;
• professional conduct standards set by the Health and Care Professions Council (“HCPC”) and the Royal College of Speech and Language Therapists (“RCSLT”); and
• all other relevant UK legal requirements.

This policy applies to all clients, prospective clients, corporate clients, workshop attendees, training participants, website users, and any individual engaging with The Speech Coach Limited.

This policy constitutes our Privacy Notice for the purposes of Articles 13 and 14 UK GDPR and should be read alongside any engagement agreement and our Terms & Conditions.

2.Professional Standards & Safeguarding

The Speech Coach provides two distinct categories of service, each governed by different professional frameworks:

2.1 Regulated Speech and Language Therapy

Where The Speech Coach provides regulated speech and language therapy services, those services are delivered in accordance with the HCPC Standards of Conduct, Performance and Ethics and RCSLT professional guidelines. In this context, HCPC registration imposes binding professional, ethical, and confidentiality obligations.

2.2 Communication & Executive Coaching

Where The Speech Coach provides communication coaching, executive presentation coaching, or advisory services that do not constitute regulated clinical practice, those services are informed by the professional standards of the HCPC and RCSLT as a framework of best practice, but do not constitute regulated therapeutic intervention. Clients engaging for coaching purposes should note this distinction.

In all cases, The Speech Coach holds a current Enhanced DBS (Disclosure and Barring Service) certificate, renewed in accordance with applicable safeguarding guidance, and applies rigorous safeguarding obligations across all engagements.

3.Data Controller

The Data Controller responsible for your personal data is The Speech Coach Limited, registered in England and Wales, Company No. 11516901, Second Floor, 34 Lime Street, London EC3M 7AT. Website: www.thespeech.coach. Email: info@thespeech.coach. ICO Registration Number: ZA754577.

If you have any questions about how your personal data is processed, please contact us using the details above.

4.Categories of Personal Data Collected

Depending on the nature of your engagement, we may collect and process the following categories of personal data:

4.1 Identity & Contact Information

• Full name, professional title, organisation or company;
• Contact details including email address, telephone number, and postal address;
• Billing and payment information (payment card data is handled directly by Stripe and is not stored by us).

4.2 Coaching & Assessment Information

• Communication goals, speech and delivery observations;
• Behavioural observations, developmental feedback, and coaching analysis;
• Session notes, submitted exercises, and documents.

4.3 Special Category Data

In the course of coaching or therapy engagements, you may voluntarily disclose information constituting special category data under Article 9 UK GDPR, including health-related information, disability, neurodivergence, or mental health conditions. Where we deliver regulated speech and language therapy, health data will necessarily form part of the clinical record.

Such data is processed only where you have provided explicit consent (Article 9(2)(a) UK GDPR), where processing is necessary for the provision of health or social care (Article 9(2)(h)), or where another Article 9 condition applies. We will not seek to elicit such information unnecessarily.

4.4 Correspondence & Website Forms

• Emails, messages, intake forms, questionnaires, submitted materials, and scheduling information;
• Information you submit through forms on our website, such as your name, email, telephone number, who the coaching is for, the programme you would like to discuss, how you found us, and your message, or your request for The Coaching Room library.

4.5 Technical & Website Information

• IP address, browser and device information;
• Cookies, analytics and advertising measurement data; website usage information.

Please refer to our Cookie Policy for further detail.

4.6 Audio & Visual Information

Where sessions are recorded, recordings may include image, video, audio, speech, behavioural observations, and information voluntarily shared during sessions. Full details of our recording practices are set out in Section 8.

5.Purposes of Processing

Personal data is processed solely for the following legitimate professional purposes:

• Delivering coaching, advisory, and regulated speech and language therapy services;
• Responding to enquiries and sending resources you request;
• Communication analysis, developmental feedback, and session preparation and follow-up;
• Maintenance of clinical and coaching records;
• Administration, scheduling, invoicing, and accounting;
• Measuring the performance of our website and advertising, where you have consented;
• Safeguarding and child protection;
• Maintaining professional, regulatory, and HCPC/RCSLT standards; and
• Compliance with legal obligations.

6.Lawful Basis for Processing

We process personal data under one or more of the following lawful bases under Article 6 UK GDPR:

6.1 Contractual Necessity (Article 6(1)(b))

Processing necessary to deliver coaching, advisory, or regulated therapy services pursuant to our engagement, or to take steps at your request before entering into one.

6.2 Legitimate Interests (Article 6(1)(f))

Processing carried out in pursuit of our legitimate interests in responding to enquiries, professional administration, service quality, communication analysis, safeguarding, and operational management, where such interests are not overridden by your interests or fundamental rights and freedoms. We have conducted Legitimate Interests Assessments (LIAs) in respect of processing carried out on this basis. A summary is available on request by contacting info@thespeech.coach.

6.3 Recognised Legitimate Interests (Article 6(1)(ea))

Where processing is necessary for safeguarding a vulnerable individual, responding to an emergency, or detecting, investigating or preventing crime, we may rely on the recognised legitimate interests introduced by the Data (Use and Access) Act 2025.

6.4 Consent (Article 6(1)(a))

Where specific consent is required, including for testimonials, recordings used beyond standard coaching analysis, non-essential cookies, or special category data where Article 9(2)(a) applies, we will obtain your explicit consent prior to such processing.

You may withdraw consent at any time by contacting info@thespeech.coach. Withdrawal of consent will not affect the lawfulness of processing carried out prior to withdrawal.

6.5 Legal Obligation (Article 6(1)(c))

Processing necessary to comply with our legal and regulatory obligations, including under tax, accounting, and safeguarding legislation.

6.6 Vital Interests (Article 6(1)(d))

In limited circumstances, particularly in connection with safeguarding obligations, we may process personal data to protect the vital interests of a data subject or another person.

7.Confidentiality

All coaching sessions, therapy sessions, communications, recordings, materials, notes, and discussions are treated as strictly confidential.

Information will not be disclosed to third parties unless:

• we are legally required to do so;
• disclosure is operationally necessary and proportionate;
• safeguarding obligations require disclosure; or
• explicit prior written consent has been obtained from you.

This duty of confidentiality extends to commercially sensitive, personal, strategic, financial, investment-related, political, proprietary, or reputationally sensitive information shared during sessions.

7.1 Safeguarding Exceptions

Where we have reasonable grounds to believe that disclosure is necessary to prevent serious harm to you, to a child, or to a third party, we may be required, and in some circumstances legally obliged, to share information with appropriate statutory authorities, safeguarding bodies, or other relevant professionals, notwithstanding our general confidentiality obligations. Where possible and appropriate, we will inform you before making such a disclosure. Our safeguarding obligations take precedence over general confidentiality duties where a conflict arises.

In the context of regulated therapy with children and young persons, our obligations under Working Together to Safeguard Children 2023, the Children Act 1989, and the Children Act 2004 apply in full.

8.Session Recordings

8.1 Purpose of Recordings

Sessions may be audio and/or video recorded for the following purposes:

• Note-taking and session accuracy;
• Coaching and communication analysis;
• Behavioural observation and developmental review; and
• Preparation of follow-up recommendations.

Recordings are used exclusively within the coaching or therapy context for the benefit of the individual client.

8.2 Lawful Basis for Recording

Session recordings are processed on the basis of our legitimate interests (Article 6(1)(f) UK GDPR) in providing accurate, high-quality services, or on the basis of contractual necessity (Article 6(1)(b)), as applicable. Where recordings involve special category data, we will obtain your explicit consent (Article 9(2)(a)) or rely on another applicable Article 9 condition.

8.3 Notification of Recording

We will take reasonable steps to notify you before a session is recorded. This may include written notice in engagement communications, verbal notification at the outset of the session, or automatic notifications generated by video conferencing platforms (Zoom, Microsoft Teams, Google Meet). You are always invited to raise any concerns about recording before or at the outset of a session, and we will seek to accommodate reasonable requests.

8.4 Confidentiality & Restricted Use of Recordings

Session recordings are treated as strictly confidential and securely stored. Recordings will not be publicly shared, distributed externally, sold, published, licensed, used for marketing, or uploaded into AI systems or datasets, without your explicit prior written consent.

All session recordings, whether held internally or supplied to a client, remain at all times the exclusive property of The Speech Coach Limited as both an internal business record and a work of intellectual property (see Section 9). Recordings are not, save where expressly agreed in writing as part of the coaching deliverable or where required by an exercise of statutory rights under the UK GDPR, supplied or released to clients as a matter of course.

8.5 Your Rights in Relation to Recordings

Nothing in this policy limits or excludes your statutory rights under the UK GDPR and the DPA 2018, including your right of access under Article 15 UK GDPR. You may submit a Subject Access Request to obtain a copy of personal data we hold about you contained within recordings (see Section 14).

Where a request is, in our reasonable assessment, manifestly unfounded or excessive, or where you request further copies, we reserve the right to charge a reasonable fee based on our administrative costs in accordance with Articles 12(5) and 15(3) UK GDPR (and not by reference to the discretionary access fee in Section 8.8).

We may redact or restrict portions of recordings where necessary to protect third-party confidentiality, legally privileged material, proprietary methodologies, or the rights of others, in accordance with applicable data protection legislation.

8.6 Permitted Client Use of Recordings

Where we have expressly agreed in writing to share specific video content with you as part of the coaching deliverable (for example, performance footage agreed in advance for your review), it is supplied solely for your personal review, communication analysis, and developmental purposes. For all other recordings, access is available only on a discretionary basis subject to the fee in Section 8.8, save where you are exercising statutory rights (in which case Section 8.5 applies).

Recordings provided to you may not be redistributed, commercially exploited, shared publicly, uploaded into AI systems (including Read AI, ChatGPT, Claude, Microsoft Copilot, or similar), or used for any external educational or commercial purpose without our explicit prior written permission.

8.7 Retention of Recordings

Session recordings are retained securely for 90 days from the date of the session and are then permanently deleted, unless a longer retention period has been expressly agreed in writing or is required by an overriding legal, regulatory, professional, or safeguarding obligation. This period is the minimum reasonably necessary for note-taking and follow-up, communication analysis, quality assurance and professional reflection, the handling of any complaint or dispute, and compliance with professional standards. Earlier deletion may be requested by contacting info@thespeech.coach and will be carried out promptly, subject to any overriding obligation and any open complaint, dispute, or investigation.

8.8 Recording Access Fee

Outside (i) any video content expressly agreed in writing to form part of the coaching deliverable, and (ii) the exercise of statutory rights under the UK GDPR, a discretionary administrative access fee of £750 per recording is payable to access, view, or obtain a copy of a recording. This fee:

• is payable per recording, namely per session recorded, irrespective of duration, length, or format;
• reflects the reasonable administrative cost of locating, retrieving, reviewing, redacting (where necessary), securely preparing, and transmitting the recording;
• is payable in advance in cleared funds, with no recording being released until payment has been received in full; and
• is non-refundable once the request has been actioned.

This fee does not apply to, and shall not be charged in respect of, the lawful exercise of statutory rights under the UK GDPR, including a Subject Access Request under Article 15.

9.Intellectual Property & Restricted Use

All methodologies, frameworks, coaching systems, exercises, analyses, recordings, observations, reports, notes, strategic models, and educational materials created or provided by The Speech Coach Limited are and shall remain its exclusive intellectual property, unless otherwise agreed explicitly in writing.

Materials are provided exclusively for your private developmental use and may not, without our explicit prior written permission, be:

• reproduced, redistributed, adapted, published, or commercially exploited;
• licensed, shared externally, or used for internal organisational training;
• incorporated into third-party programmes or used to create derivative products or systems; or
• uploaded into or processed by any AI or machine learning system.

No transfer of intellectual property ownership is implied or effected through participation in sessions, receipt of recordings, materials, analyses, or strategic recommendations. All rights not expressly granted are reserved.

10.Artificial Intelligence: Internal Use & Client Restrictions

10.1 AI Tools Used Internally

We use the following AI-assisted tools to support the delivery of our services, solely for internal professional purposes and subject to appropriate contractual restrictions with each provider:

Confidential client content, recordings, and session data are not uploaded into these tools without your prior written consent. Where any AI tool is used to process personal data relating to you, this will be disclosed to you at the time. We do not use client recordings or confidential coaching materials to train public AI models or to create commercial AI datasets.

10.2 Client Restrictions on AI Use

Client materials, session recordings, coaching notes, strategic analyses, frameworks, exercises, methodologies, and intellectual property provided by The Speech Coach Limited may not be uploaded into or processed by any AI or machine learning system, including (without limitation) Read AI, ChatGPT, Claude, Microsoft Copilot, Google Gemini, Otter, Fireflies, or Notion AI, without our explicit prior written consent.

11.Third-Party Platforms, Processors & Data Sharing

11.1 Data Processors

We engage carefully selected third-party service providers (data processors) to support our services, under Data Processing Agreements as required by Article 28 UK GDPR, so that personal data is processed only on our documented instructions and with appropriate security measures. Our processors include:

11.2 Online Platforms: Inherent Risks

While we use reputable and established platforms, no internet-based communication system can be guaranteed entirely secure, and inherent technical and cybersecurity risks exist. Clients participate in remote sessions at their own discretion.

11.3 Employer-Funded or Third-Party Funded Engagements

Where coaching or therapy is funded by an employer, organisation, family office, or third party, coaching discussions remain confidential to the client unless otherwise agreed explicitly in writing. Any summaries or reports provided to a funding organisation will be limited, agreed with you in advance, and will not disclose private coaching or clinical content without your consent, unless legally required.

11.4 Third-Party Information Disclosed by Clients

You remain solely responsible for ensuring you have lawful authority to disclose any confidential, proprietary, commercially sensitive, or third-party information during sessions. We accept no liability for unauthorised disclosures made by you.

12.Data Retention

Personal data is retained only for as long as necessary for the purposes for which it was collected, in accordance with the storage limitation principle (Article 5(1)(e) UK GDPR).

Retention periods may be extended where required by applicable law, regulatory obligation, safeguarding requirements, or where a legal dispute is anticipated or ongoing.

13.Security Measures

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, misuse, disclosure, accidental loss, destruction, or alteration, in accordance with Article 32 UK GDPR. Measures include:

• Password protection, two-step verification and restricted-access systems;
• Encrypted storage and secure transfer methods for audio, video, and sensitive files;
• Use of reputable, DPA-compliant cloud platforms for file storage and transfer;
• Device security protocols; and
• Awareness of data protection obligations in the conduct of our services.

13.1 Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner’s Office (ICO) within 72 hours of becoming aware of the breach, in accordance with Article 33 UK GDPR. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay under Article 34 UK GDPR. All breaches, whether or not meeting the reporting threshold, are logged internally.

14.Your Data Protection Rights

Under the UK GDPR and the DPA 2018, you have the following rights in respect of your personal data:

• Right of Access (Article 15): to obtain a copy of the personal data we hold about you;
• Right to Rectification (Article 16): to have inaccurate or incomplete data corrected;
• Right to Erasure (Article 17): to request deletion of your data in certain circumstances;
• Right to Restriction of Processing (Article 18): to restrict how we process your data in certain circumstances;
• Right to Data Portability (Article 20): to receive your data in a portable, machine-readable format in certain circumstances;
• Right to Object (Article 21): to object to processing based on legitimate interests or for direct marketing; and
• Right to Withdraw Consent: where processing is based on consent, to withdraw that consent at any time without detriment.

Where you object to processing based on our legitimate interests, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests or the processing is necessary for legal claims.

14.1 Automated Decision-Making

We do not make decisions about you based solely on automated processing (including profiling) that produce legal or similarly significant effects.

14.2 How to Exercise Your Rights

To exercise any of your rights, please contact info@thespeech.coach. Proof of identity may be required. We will respond within one calendar month of receipt; where requests are complex or numerous, this may be extended by up to two further months, in which case we will tell you within the first month. Where we need further information to identify the data you are asking for, the time limit runs from when we receive it. In responding to access requests we carry out reasonable and proportionate searches.

For manifestly unfounded or excessive requests, we may charge a reasonable fee based on our administrative costs (minimum £10), or refuse the request, in accordance with Article 12(5) UK GDPR. We will tell you how any fee is calculated before it is charged.

14.3 Complaints

If you are unhappy with how we have handled your personal data, please contact us first at info@thespeech.coach with “Data protection complaint” in the subject line. We will acknowledge your complaint within 30 days of receipt, investigate it without undue delay, and tell you the outcome.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority: ico.org.uk, helpline 0303 123 1113, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

15.International Data Transfers

Several of our processors operate from, or transfer data to, countries outside the United Kingdom, including the United States. Where personal data is transferred internationally, we ensure appropriate safeguards are in place in accordance with Chapter V UK GDPR, including:

• UK adequacy regulations, for transfers to countries recognised as providing adequate protection (including EEA member states);
• International Data Transfer Agreements (IDTAs), the ICO-approved contractual mechanism for transfers from the UK; and
• the UK Addendum to the EU Standard Contractual Clauses, where processors have implemented EU SCCs.

Please refer to the processor tables in Sections 10.1 and 11.1. Further details are available on request.

15.1 Clients Outside the United Kingdom

We coach clients around the world. If you are based outside the United Kingdom, your personal data will be processed in the United Kingdom and in the countries listed above. Where you are in the European Economic Area and the EU General Data Protection Regulation applies to our processing of your data, we will honour the equivalent rights it gives you, and you may also complain to the data protection authority in your country.

16.Children & Young Persons

The coaching and therapy of children and young persons (under 18 years of age) is a regular part of our practice. Where we work with minors:

• Parental or guardian consent will be obtained before processing the minor’s personal data, save where applicable safeguarding legislation provides otherwise;
• Enhanced safeguarding obligations apply in full, including those under the Children Act 1989, the Children Act 2004, and Working Together to Safeguard Children 2023;
• Clinical records for minors are retained in accordance with HCPC standards and NHS Records Management guidance;
• Parents or guardians are responsible for appropriate supervision in relation to online sessions involving minors; and
• Any safeguarding concerns will be handled in accordance with our safeguarding obligations, which may require disclosure to statutory bodies without prior notification.

We will not knowingly process personal data of children under 13 years of age via our website without verifiable parental or guardian consent.

17.Marketing & Testimonials

Client names, session content, recordings, testimonials, endorsements, screenshots, images, or any identifiable information will not be used publicly without your explicit prior written consent. Participation in coaching or therapy does not constitute consent to marketing or promotional use of your information.

Where you provide a testimonial, you consent to its use for the specific purposes agreed in writing. You may withdraw this consent at any time by contacting info@thespeech.coach.

We do not add anyone to a marketing or mailing list without asking first.

18.Cookies, Analytics & Advertising Measurement

Our website uses cookies and similar technologies to operate the site, remember your choices, measure how it is used and, with your consent, measure the effectiveness of our advertising. We ask for your consent before setting non-essential cookies, in accordance with PECR and the UK GDPR, and you can change your choices at any time using the cookie settings.

Where you have consented to marketing cookies and you submit a form on our website, Google Ads may receive a hashed (encrypted) form of your email address so that we can measure whether our advertising led to the enquiry. Google cannot read the original address from the hash.

Full details of every cookie we use are in our Cookie Policy.

19.Limitation of Liability

Coaching, communication analysis, strategic observations, and developmental guidance are advisory in nature. You remain solely responsible for your own decisions, actions, communications, investments, negotiations, business outcomes, and the implementation of any advice received.

The Speech Coach Limited provides regulated speech and language therapy services where expressly agreed. Outside of that context, we do not provide legal advice, financial advice, investment advice, psychiatric treatment, or psychotherapy. No guarantees are provided regarding specific personal, financial, commercial, or professional outcomes.

The Speech Coach Limited shall not be liable for:

• any loss arising from your own decisions or implementation of coaching advice;
• unauthorised onward sharing of recordings or materials by you;
• your misuse of coaching or therapy materials; or
• security breaches arising from your own storage, transfer, or handling of personal data following lawful disclosure to you.

Nothing in this policy limits or excludes our liability for death or personal injury caused by our negligence, for fraud or fraudulent misrepresentation, or for any other liability that cannot lawfully be excluded or limited under English law.

20.Changes to This Policy

This policy may be updated periodically to reflect legal developments, operational changes, regulatory requirements, safeguarding obligations, and evolving best practice. The current version is always published at thespeech.coach/privacy-policy and applies from the stated effective date. Where changes are material, we will take reasonable steps to notify existing clients.

21.Severability

If any provision of this policy is found to be unlawful, void, or unenforceable, that provision shall be deemed severable and shall not affect the validity and enforceability of the remaining provisions.

22.Accuracy of Personal Data & Client Warranties

We rely on the accuracy of personal data provided by clients and corporate clients. You are responsible for ensuring that all personal data you provide to us is accurate, complete, and kept up to date. We are not liable for any consequences arising from the processing of inaccurate or incomplete data submitted by you or on your behalf.

Where a corporate client shares personal data relating to employees, delegates, or other individuals with us, the corporate client warrants that: (a) it has a lawful basis under the UK GDPR for sharing that data; (b) appropriate privacy notices have been provided to those individuals; and (c) it indemnifies The Speech Coach Limited against any claim, loss, or regulatory action arising from a breach of this warranty.

23.Third-Party Websites, Social Media & External Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices, data processing activities, or content of those sites.

Where you contact us via social media platforms (including LinkedIn, Instagram, YouTube, TikTok, Facebook, or WhatsApp), any personal data submitted through those platforms will be processed in accordance with this policy. Those platforms operate under their own terms and privacy policies.

Where voice, speech, or communication data is processed using AI-assisted tools (as described in Section 10), such data may constitute biometric or health-related data in some contexts. Where this applies, explicit consent will be sought before processing.

24.Coach Privacy & Personal Information

All personal information relating to any Coach that a client may incidentally acquire during the course of their engagement, including information relating to the Coach’s family, relationships, home, lifestyle, health, finances, beliefs, opinions, or personal circumstances, is treated as strictly private and confidential under this policy and under the confidentiality provisions of our Terms & Conditions.

Coach personal data is held securely, is accessible only to authorised personnel, and is not shared with clients beyond what is strictly necessary for booking and service delivery. Any client who processes, shares, or discloses Coach personal information without authorisation may be in breach of the UK GDPR, the DPA 2018, and the law of confidence.