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Privacy Policy

Last Updated: 25 August 2026

 

1. Who We Are

This privacy notice explains how Freedom to Thrive Coaching/ Ben Curran ("I", "me", or "my") collects, uses, stores, and protects your personal information when you use my website, enquire about services, or undergo Life Coaching and Emotional Freedom Technique (EFT) sessions.

  • Data Controller: Ben Curran

  • Trading Address: 25 Great Eastern Court, Norwich, Norfolk, NR11EQ

  • Contact Email: ben@freedomtothrivecoaching.com

  • ICO Registration Reference: ZC105413

 

2. The Information I Collect

I process different types of information depending on your interaction with my practice:

  • Basic Personal Data: Full name, phone number, email address, date of birth, emergency contact details, and billing/payment information.

  • Special Category (Health & Emotional) Data: Notes, intake forms, and reflections related to your emotional, psychological, or physical well-being, personal goals, past experiences, and session responses gathered during coaching and/ or EFT tapping sessions.

  • Technical Data: IP address, browser type, and cookies collected automatically when visiting my website.

 

3. How & Why I Process Your Data (Lawful Bases)

Under UK GDPR, I must have a valid legal reason to process your information:

Data Category

Purpose

UK GDPR Lawful Basis

Contact & Financial

Scheduling sessions, managing payments, and fulfilling our coaching contract.

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

Administrative & Legal

Retaining business accounting records and maintaining tax records for HMRC.

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

Session Notes & EFT Data

Tailoring coaching sessions, tracking your progress, and maintaining professional safety standards.

Explicit Consent (Article 6(1)(a) & Article 9(2)(a) for Special Category Data)

 

4. Confidentiality & Data Sharing

Your session information and personal notes are strictly confidential. I do not sell, rent, or trade your personal data.

I will only share your information under the following limited circumstances:

  • Explicit Request: When you explicitly authorize me to share information with another health professional.

  • Professional Supervision: As a practicing practitioner, I regularly attend professional supervision. Client details are always completely anonymized during supervision to protect your identity.

  • Legal Exceptions & Safeguarding: Where I am legally compelled to do so, such as under a court order, or if I reasonably believe there is a serious, immediate risk of harm to yourself or others.

  • Third-Party Service Providers: I use trusted GDPR-compliant digital tools to process operational data.

 

5. How Your Data Is Stored & Secured

I am committed to keeping your information safe:

  • Digital Data: Stored using password-protected, encrypted cloud services and secure hardware protected by multi-factor authentication.

  • Paper Records: Any physical intake forms or hand-written session notes are stored securely in a locked filing cabinet within locked premises.

  • International Transfers: Where third-party tools store data outside the UK (e.g., US cloud services), I ensure appropriate safeguards are in place to preserve your UK GDPR rights.

I also have procedures in place to deal with any suspected data security breach. I will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

 

6. Retention (How Long I Keep Your Data)

  • Client Records & Session Notes: Retained for 7 years following the completion of our final session to satisfy professional indemnity insurance requirements and handle any potential claims. After this period, records are permanently erased or shredded.

  • Financial & Accounting Records: Retained for 6 tax years following the end of the current tax year to comply with HMRC obligations.

  • General Enquiries: Kept for 6 months if you do not proceed with coaching, after which they are deleted.

 

7. Your Statutory Rights

Under UK data protection law, you have specific rights regarding your data:

  • Right of Access: Request a copy of the personal data held about you.

  • Right to Rectification: Request corrections to inaccurate or incomplete data.

  • Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data (subject to legal or insurance retention obligations).

  • Right to Withdraw Consent: Where processing is based on explicit consent you may withdraw consent at any time.

  • Right to Restrict or Object: Limit or object to how your data is processed.

To exercise any of these rights, please email me. I will respond within one calendar month.

 

8. How to Complain

If you have concerns about how your data is handled, please contact me first so I can resolve the issue.

You also have the right to lodge a complaint directly with the UK supervisory authority:

  • Information Commissioner’s Office (ICO)

  • Website: ico.org.uk

  • Helpline: 0303 123 1113

 

9. Changes to this privacy policy

This privacy policy was published on 26th August 2026 and is subject to regular review.

We may change this privacy policy from time to time, when we do we will inform you via our website

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