Privacy Notice

RISING PATHWAYS COACHING

Creating Space for Growth

Rising Pathways Coaching provides coaching services to adults aged 18 and over only.This notice explains how personal information is handled when you enquire about or receive coaching.This notice also covers use of the Rising Pathways website, Leadership & Career Mentoring, Coaching for Coaches, free resources, digital products, bookings, purchases and related customer support.Rising Pathways Coaching currently provides paid coaching, mentoring and paid digital products only to customers resident in the United Kingdom.Rising Pathways Coaching is based in Devon, England, and this notice explains how personal information is handled under applicable UK data-protection law.Rising Pathways coaching and mentoring sessions will not be recorded or AI-transcribed. We will not ask for medical diagnoses, NHS numbers, GP details, medication, medical records or detailed medical history.

Who is responsible for your information?

Rising Pathways Coaching is responsible for deciding how personal information used in the business is handled. Niamh, owner of Rising Pathways Coaching, has overall responsibility for data protection and information governance.
For the purposes of UK data-protection law, Niamh Ramachandran trading as Rising Pathways Coaching is the controller of the personal information described in this notice.
Business address: 95 Younghayes Road, Cranbrook, Exeter EX5 7DR.
Contact: [email protected]

What information may be collected?

Coaching enquiry

• Name
• Email address
• Brief reason you are interested in coaching
• Accessibility or communication adjustments you choose to tell us about
If you become a client, Rising Pathways may also hold the minimum information needed to administer and provide your coaching, including your RPC client reference, signed agreement, intake information, session dates, invoices/payment status, proportionate coaching notes, agreed tools/exercises and relevant correspondence or documents.

Mentoring and Coaching for Coaches

If you receive Leadership & Career Mentoring or Coaching for Coaches, Rising Pathways may hold the same types of proportionate client-administration information needed to provide that service, together with information you choose to share about your goals, work or professional context.

Website visitors

When you visit the Rising Pathways website, the website provider and connected services may process limited technical information such as IP address, browser or device information, security/log information and information about how the website is accessed.

Free resources and digital-product customers

If you request a free resource or purchase a digital product, Rising Pathways and its e-commerce providers may process information such as your name, email address, billing country or location, the resource or product requested, order/download date, transaction amount and status, refund information, where applicable.
Rising Pathways does not receive or store your full payment-card details. Payment information is handled by the payment processor made available through the checkout platform.

Health, disability and other sensitive information

Clients are welcome to discuss how disability, chronic illness or health circumstances affect their goals, confidence, work, identity, leadership or life changes when relevant to their coaching or mentoring.
The same data-minimisation approach applies where health, disability or accessibility information is relevant to Leadership & Career Mentoring or Coaching for Coaches.
Rising Pathways will not request or routinely hold:
• Medical records
• GP or consultant letters
• Test results
• Medication lists
• NHS numbers
• Detailed medical histories
• Clinical photographs or documents
Rising Pathways does not provide medical assessment, diagnosis, treatment recommendations or nursing advice through the coaching or mentoring relationship. This non-clinical boundary also applies to Coaching for Coaches, digital resources and public educational content.

How and why we use your information?

Rising Pathways Coaching uses personal information only where there is a lawful basis for doing so.

Providing and administering coaching, mentoring and Coaching for Coaches

Where information is necessary to respond to your request, enter into an agreement, arrange and provide sessions, communicate with you about the service, and administer the client relationship, the lawful basis is contract or taking steps at your request before entering into a contract.

Legal and financial obligations

Where information must be kept or used to comply with a legal obligation, such as applicable tax and accounting requirements, the lawful basis is legal obligation.

Health, disability and other health-related information

You do not have to provide health or disability information to receive coaching or mentoring. Where you choose to provide health, disability or other health-related information because it is relevant to your service or an accessibility adjustment, Rising Pathways uses contract as the Article 6 lawful basis where that information is necessary to provide or adapt the service you have requested, and explicit consent under Article 9(2)(a) as the additional condition for processing this special-category information.
Your explicit consent is obtained separately through the Rising Pathways intake/consent process. The Privacy Notice itself is not treated as consent.
You may withdraw your explicit consent for the use of health, disability or other health-related information at any time by contacting [email protected]. Withdrawal does not affect processing that was lawful before consent was withdrawn. If consent is withdrawn, Rising Pathways will stop using that information on the basis of consent and will consider what information can and should be securely deleted, subject to any separate legal requirement or lawful basis that applies.

Website operation and security

Where limited personal information is processed to operate, maintain and protect the website and business systems, Rising Pathways relies on legitimate interests in running a safe, functional and proportionate online business, except where consent is legally required for a particular technology.

Free resources

Where you ask Rising Pathways to send or provide access to a free resource, the lawful basis is legitimate interests in responding to your request, administering the download and providing reasonable support connected with that resource.
Rising Pathways is not currently operating an email marketing or newsletter list. Requesting a free resource does not sign you up for marketing, and your email address will not be used for a newsletter simply because you requested a free resource. If Rising Pathways introduces email marketing in future, this notice will be updated and any consent or other steps required by law will be put in place before marketing begins.

Paid digital products

Where you purchase a digital product, personal information is used as necessary to process and administer the order, provide access or delivery, communicate about the purchase and provide customer support. The lawful basis is contract or taking steps at your request in connection with the purchase. Legal obligation may also apply to tax, accounting and other records that must be retained.

Discovery calls

During a discovery call, brief temporary prompts may be made to help conduct the conversation. No detailed account, medical history or transcript is created.
If you do not become a client, those temporary prompts are deleted within one month of the discovery call.
If you become a client, only the minimum information that is relevant and necessary for the client relationship is transferred into your record, and the temporary discovery-call prompts are then deleted.

Coaching and mentoring records and emails

For Leadership & Career Mentoring and Coaching for Coaches, records are kept to the same principles of relevance, proportionality and data minimisation as general coaching records.
Client records are kept factual, respectful, relevant, proportionate and focused on the service. A client reference is used in notes and other records wherever practical to reduce unnecessary use of your name.
Routine client emails do not automatically become part of the client record. If an email contains something genuinely relevant to the ongoing work, only the necessary point is transferred into the notes.
Tailored or completed tools may be retained with your client record where they form a meaningful part of the work. Generic blank tools remain part of the Rising Pathways resource library.

Confidentiality and its limits

Client information stays confidential except where:
• you have authorised disclosure;
• disclosure is required by law;
• there is a sufficiently serious concern about harm or safety where disclosure is justified; or
• professional coaching supervision is used, in which case only the minimum necessary information is shared and the client is not identified wherever possible.
Where there is a serious concern about your safety or the safety of another person, Rising Pathways may need to take appropriate action or share relevant information where necessary or required by law. Wherever appropriate and safe to do so, the aim would be to discuss this with you first.

Professional coaching supervision

As part of my commitment to ethical and reflective practice, I undertake regular professional coaching supervision with another coach.
I may discuss appropriately anonymised aspects of 1:1 Coaching, Leadership & Career Mentoring or Coaching for Coaches during supervision for the purposes of reflection, maintaining professional standards and supporting safe and ethical practice.
Wherever possible, information shared in supervision will be anonymised and limited to what is reasonably necessary. I will not disclose a client's name or other information that would reasonably identify them.

Training, accreditation and professional development

Rising Pathways may use appropriately anonymised information from coaching or mentoring practice for legitimate coaching training, accreditation and professional-development requirements.
This may include anonymised extracts or summaries derived from session notes, approaches or tools used, decision-making, reflective practice and learning.
Information will be limited to what is reasonably necessary and anonymised so that the client is not reasonably identifiable. Client names, RPC/RPM/RPCC references, contact details and other direct identifiers will not be included.
Rising Pathways will not provide identifiable client records or recordings simply for training or accreditation purposes. If a particular requirement genuinely requires identifiable information or something beyond this anonymised use, that requirement will be considered separately before disclosure.

How we communicate and use technology

• Rising Pathways business email is used for administration, brief coaching or mentoring updates and agreed exercises/tools or resources.
• Microsoft Teams is used for online discovery calls, coaching and mentoring sessions.
• Microsoft Bookings is used for appointment scheduling. It is not used as a coaching or mentoring record or intake system.
• Microsoft Forms may be used to collect optional client feedback and other service-related responses. Submitting feedback does not by itself give Rising Pathways permission to publish it as a testimonial or case study.
• Social media may be an entry point for enquiries, but coaching, mentoring and confidential matters move into the Rising Pathways business system.
• WhatsApp, SMS and a personal mobile number are not routine client communication channels.
• Identifiable client information, notes, client emails, intake forms, session content or confidential client material are not entered into generative AI tools.
Rising Pathways uses Microsoft 365 as its core business technology platform, including Outlook for business email, OneDrive for cloud file storage, Microsoft Teams for online meetings, Microsoft Bookings for appointment scheduling and Microsoft Forms for optional feedback and other service-related forms.
The Rising Pathways website is hosted using Carrd. Carrd and the services used to deliver the website may process limited technical data required to provide, protect and operate the website.
Payhip is used for digital-product storefront, checkout, free-resource delivery and order/customer administration. Payhip may process customer information needed to provide those functions. Payment is handled separately through the payment processor selected or made available during checkout, and Rising Pathways does not receive full payment-card details.
Where a third-party service is used, that provider may also process information under its own privacy information and legal obligations.

Cookies and analytics

Rising Pathways does not currently intentionally use optional website analytics or advertising tracking. Only cookies or similar technologies needed for the website and connected services are intended to be used at launch.
If optional analytics, advertising pixels or other non-essential tracking are deliberately enabled in future, Rising Pathways will update its privacy/cookie information and put in place any consent mechanism required by UK law before using those technologies.
Links to third-party services such as Payhip, Spotify or social-media platforms take you to services with their own cookie and privacy practices.

Who your information may be shared with

Rising Pathways does not sell client personal information. Personal information is shared only where necessary and proportionate. This may include service providers that process information on behalf of Rising Pathways in providing business email, cloud storage, online meetings and appointment scheduling; professional coaching supervision as described above; professional advisers such as accountants, insurers or legal advisers where necessary; and public authorities, regulators, courts or other organisations where disclosure is required or permitted by law or is necessary in connection with a serious safety concern or legal claim.
This applies equally to website visitors, enquirers, free-resource downloaders, digital-product customers and coaching, mentoring or Coaching for Coaches clients.
Relevant service providers may include Microsoft 365 (business email, storage, meetings, bookings and forms), Carrd (website hosting), Payhip (storefront, checkout, digital delivery and order administration), and the payment processor used at checkout. Only information reasonably necessary for the relevant function should be shared.

International transfers

Rising Pathways Coaching uses Microsoft 365 and other third-party providers. Some personal information may be processed or transferred outside the UK as part of the operation and support of those services.
Where personal information is transferred outside the UK, appropriate safeguards are used as required by UK data-protection law. These may include UK adequacy regulations or approved contractual safeguards for international transfers.
Other providers used by Rising Pathways may also process or store personal information outside the UK. Where a restricted international transfer occurs, Rising Pathways will rely on an appropriate lawful transfer mechanism and safeguards where required.

Information about other people

If you discuss a partner, relative, colleague, manager, coaching client or another person during coaching or mentoring, Rising Pathways records only the minimum information genuinely necessary to understand the context. Their identities will generally not be recorded unnecessarily.
For Coaching for Coaches, you should use anonymised and proportionate information about your own clients or other third parties wherever possible and avoid sharing names, contact details, records or other information that is not reasonably necessary.

Testimonials, case studies and feedback

Nothing from your coaching or mentoring is used publicly by default. Feedback is optional and private by default.
Microsoft Forms may be used to collect optional feedback. Information submitted through a form is handled in accordance with this Privacy Notice. Private feedback will remain private unless you separately give permission for a testimonial, quote or case study to be used publicly.
If Rising Pathways later wishes to use a testimonial, quote or case study publicly, a separate consent process will be used. You may choose private feedback only, an anonymous testimonial, first name only, full name, or specific permission for a case study. Saying no has no effect on your service.

How long information is kept

• Temporary discovery-call prompts: deleted within 1 month if you do not become a client; if you do become a client, only necessary information is transferred and the prompts are deleted.
• Basic unsuccessful-enquiry correspondence: no longer than 3 months after the last meaningful contact, unless there is a documented legal or operational reason requiring longer retention.
• Coaching/mentoring content records, client-specific exercises/tools and intake forms: retained during the client relationship and for 2 years after it ends, then reviewed and securely deleted unless there is a documented reason for continued retention.
• Signed coaching or mentoring agreements and essential contractual records: 6 years after the client relationship ends.
• Financial and tax records: the applicable HMRC record-keeping period.
• Formal complaints, disputes, safeguarding matters and actual or potential legal claims: held separately for as long as reasonably necessary, taking account of applicable limitation periods and insurer requirements.
• Evidence of testimonial or case-study permission: retained while Rising Pathways is using that material publicly.
• Digital-product order, refund and transaction-administration records: retained for the period reasonably required for contract administration and applicable tax, accounting, consumer-law, fraud-prevention and legal-claim purposes.
• Free-resource download records where the person does not become a client or customer: retained for 24 months from the last interaction, then securely deleted unless there is a documented reason for continued retention.
When information reaches its deletion date, Rising Pathways reviews whether there is a documented reason for continued retention. If there is not, it is securely deleted and unnecessary local or downloaded copies are removed. Rising Pathways will not deliberately retain a hidden accessible copy 'just in case'.

Your data-protection rights

If you ask to access, correct, restrict, object to the use of, transfer, delete or otherwise exercise a data-protection right concerning your personal information, Rising Pathways will treat this as a formal data-rights request. You do not need to use legal terminology.
Where there is reasonable doubt about identity, proportionate steps may be taken to verify who is making the request. Passports, driving licences or other excessive identification will not be requested routinely, and copies of ID will not routinely be retained.
A request for deletion will be considered promptly in accordance with applicable data-protection rights. Information that can and should be erased will be securely deleted. Some information may need to be retained where Rising Pathways is legally entitled or required to keep it, for example certain financial records or information needed in relation to a legal claim.

Your right to object

Where Rising Pathways relies on legitimate interests, you may object to that processing in circumstances provided by data-protection law. You also have the right to object to personal information being used for direct marketing. Rising Pathways is not currently operating an email marketing or newsletter list.

Personal-data breaches

Any suspected personal-data breach is contained, documented and assessed, even where the conclusion is that external reporting is not required. Where a breach meets the applicable reporting threshold, Rising Pathways will follow the applicable data-protection requirements. Where a breach is likely to result in a high risk to an individual's rights and freedoms, the affected individual will be informed without undue delay as required by applicable law.

Contact and complaints about privacy

For questions about this notice or to exercise a data-protection right, contact: [email protected]
If you have concerns about how Rising Pathways Coaching has handled your personal information, please contact me first so I have an opportunity to address them. You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK's data-protection regulator.

Data-protection complaints process

You can make a data-protection complaint to Rising Pathways by emailing [email protected] and explaining the concern. Rising Pathways will acknowledge receipt within 30 days, make appropriate enquiries without undue delay, keep you informed where appropriate, and communicate the outcome without undue delay. You also retain the right to complain to the Information Commissioner's Office.

Information Commissioner's Office (ICO)

Website: ico.org.uk
Telephone: 0303 123 1113

Version 1.4 | Date: 4 September 2026 | Review: at least annually and sooner after a significant change.