Website and Coaching Privacy Notices

The main points

I use your details to respond to enquiries, arrange coaching, manage agreements and payments, and keep brief notes for continuity. You choose how much personal context to share and do not need a diagnosis. I keep private coaching records separate from my NHS work.

Squarespace hosts this website and helps me manage client administration, invoices and coaching agreements. Sensitive coaching notes are held separately. I do not routinely tell employers, referrers or relatives that you are a client or share session content with them.

I do not record sessions or use AI meeting assistants. Limited disclosures may be necessary for legal reasons or serious safety concerns, as explained below. Contact hello@drdarrelle.co.uk with privacy questions or requests.

Who is responsible

I am Dr Darrelle Gengasamy, trading as Dr Darrelle, and I am the data controller for this website and my independent coaching service. This means I decide why and how your personal information is used.

Email: hello@drdarrelle.co.uk

This notice covers website visitors, people who enquire about coaching, clients, nominated emergency contacts and people arranging or paying for coaching. It does not cover my NHS roles or NHS Practitioner Health records.

Information I receive

·         Website information such as your IP address, browser, device and pages accessed; cookie choices and optional analytics where enabled.

·         Your name, preferred name, email, callback number, booking details, correspondence, access preferences, coaching goals and brief notes about themes and agreed actions.

·         Agreement terms, acceptance confirmation and associated date or time records made available by the contract platform.

·         Invoice details, fee, billing information where required, payment date, transaction reference, payment status and refunds. Payment providers handle the payment information needed for your chosen method.

·         Your current session location for remote-session safety, and an optional emergency contact’s name, relationship and telephone number.

Most information comes from you. I may receive relevant information from an authorised referrer or funder, and an emergency contact’s details from the person nominating them. Please avoid sending clinical reports or identifiable information about patients or colleagues.

How and why I use your information

Enquiries and coaching

I use necessary contact details, messages, bookings, agreement acceptance records and brief coaching notes to take steps at your request before a contract and to deliver our coaching agreement. The legal basis is Article 6(1)(b) of the UK GDPR.

Invoices and accounts

I use invoice and payment details to bill for agreed services and manage payment under our contract, Article 6(1)(b). I keep required accounting and tax records to meet legal obligations, Article 6(1)(c).

Service security and concerns

I use relevant records to protect the website and service, respond to concerns and manage legal claims. My basis is legitimate interests, Article 6(1)(f), in running a safe service and protecting legal rights. I consider your interests and rights when doing so. Article 6(1)(c) applies where a specific legal obligation requires processing.

Health and other sensitive information

Information about health, disability or neurodivergence, including access information that reveals health details, receives extra legal protection. I ask for your separate explicit consent under Article 9(2)(a) before using it to tailor coaching or keeping it in brief notes. Article 6(1)(b) applies where the information is necessary for the coaching you request.

You can decline to share a diagnosis or detailed health history, ask for less detail in notes, or withdraw explicit consent by emailing me or telling me in a session. I will stop the use that depends on that consent and discuss what coaching can continue without it. Withdrawal does not affect earlier lawful use. Any necessary retention for a separate purpose must have its own valid legal basis and, for sensitive data, an Article 9 condition.

Safety during remote sessions

I use your callback number, current session location and any nominated emergency contact in my legitimate interests in arranging proportionate help if needed, Article 6(1)(f). I ask where you are at the start of each session and do not routinely retain the location afterwards. A necessary incident record may include it. An emergency contact is optional; sessions take place while you are physically in the UK.

In a life-threatening emergency, vital interests may apply, Article 6(1)(d). For sensitive information, Article 9(2)(c) applies only where the person is physically or legally incapable of consenting. Other exceptional disclosures require their own applicable legal basis and condition; a general safety concern does not automatically permit disclosure.

Choices about additional uses

I do not use identifiable coaching information for teaching, testimonials, marketing or AI training. Any future proposed use would need a separate explanation and appropriate permission or other valid legal basis. Administrative emails about your booking, contract or payment are part of providing the service.

Service providers and confidentiality

Squarespace administration

I use Squarespace to host the website and manage client contact details, coaching agreements and invoices. It receives information needed for these functions, including names, email addresses, agreement content and acceptance records, invoice line items and payment history. I keep invoices and contract records limited to administrative information and do not put detailed health histories or session notes into Squarespace projects.

Squarespace processes some information on my behalf under its Data Processing Addendum. It also uses certain information as an independent controller, including for its own platform purposes described in its privacy policy: https://www.squarespace.com/privacy.

Payments and other providers

I use Squarespace and Stripe for invoices and online payments. Depending on the payment route, they receive the billing, transaction and payment information needed to process payments, refunds, fraud checks and their legal obligations. They may act as independent controllers for some purposes. Stripe privacy information: https://stripe.com/gb/privacy. I do not ask you to send card numbers by email. For bank transfers, my bank receives and retains the transaction information.

I use Microsoft Outlook and Microsoft 365 to send and receive emails and manage associated correspondence. Microsoft processes email content, addresses, attachments and relevant service information. Microsoft privacy information: https://www.microsoft.com/privacy/privacystatement.

I use Zoom for coaching sessions and booking links embedded in or linked from my Squarespace website. Zoom processes information needed to arrange and deliver sessions, such as your name, email, booking details, audio and video, and relevant device or connection information. Where booking uses a connected calendar, relevant appointment information may also pass to Microsoft 365. Zoom privacy information: https://www.zoom.com/en/trust/privacy/privacy-statement/.

Other disclosures

I normally discuss supervision themes without information that could identify you. If identifiable information is needed for supervision, I will explain the purpose and seek separate permission before sharing unless another lawful reason applies. Removing a name alone may not make a case anonymous.

An employer, referrer or other funder is not entitled to session content simply because they pay. Any routine sharing of attendance or other information will be agreed separately with you. Billing may reveal the agreed service to the payer, and I will explain that arrangement before it starts.

I may disclose the minimum necessary information when required by law or a valid court order, or where there is a legally justified serious safety or safeguarding concern. I will usually discuss this with you first unless it would be unsafe, impracticable or defeat the purpose. Any sensitive-data disclosure must also meet an applicable Article 9 condition.

Overseas processing and offline health records

Some providers process information outside the UK, including in the United States. Squarespace’s DPA describes reliance on the UK Extension to the EU-US Data Privacy Framework for covered transfers, with contractual safeguards including the UK Addendum where required. For other providers I use [insert verified adequacy or contractual safeguard and any required transfer assessment]. You may request details or a copy of applicable safeguards by emailing me.

Offline health records

I keep saved health information and sensitive coaching notes separately on a password-protected physical hard drive. I do not upload these stored notes to cloud storage or put them in Squarespace or Stripe records. Access is restricted, and private coaching records are kept separate from NHS systems.

Information discussed during a Zoom session is transmitted through Zoom even when no recording is saved. If you send health information by email, Microsoft 365 processes and may retain that message or attachment; keeping notes offline does not remove email copies. Please avoid detailed health information in email and booking forms.

Sessions are not routinely recorded or transcribed, and I do not use AI meeting assistants. Live accessibility captions may be used without saving a transcript. Any proposed recording or saved transcript would require a separate explanation and agreement.

Retention and your rights

How long I keep information

I review records and securely delete or anonymise information when it is no longer needed. These periods apply to my records; independent payment and other providers may have their own lawful retention duties.

·         Enquiries that do not lead to coaching: six months after the last contact, unless a specific unresolved concern requires longer retention.

·         Coaching agreements, acceptance evidence and necessary brief coaching records: seven years after the last session, subject to earlier deletion where required, including following withdrawal of sensitive-data consent unless a separate lawful reason permits retention.

·         Emergency contact details: while you are the nominated contact, then delete within 30 days of replacement, withdrawal or the end of coaching, unless needed in a specific incident record.

·         Current session location: not routinely kept after the session; retained only if necessary in an incident record.

·         Required self-employed tax records: at least five years after the 31 January submission deadline for the relevant tax year; longer where a tax enquiry or another legal obligation requires it.

·         Complaint, incident and claim records: for the documented period needed to resolve the matter and manage relevant legal or insurance requirements. I review the need for continued retention.

Website cookies and similar technologies have the lifetimes listed in the cookie information.

Your choices and rights

You can ask for access, correction, deletion, restriction of use and a portable copy where applicable. You can object to processing based on legitimate interests and withdraw consent at any time. These rights depend on the purpose and legal basis; I will explain any applicable limits. I do not make solely automated decisions about you with legal or similarly significant effects.

Email hello@drdarrelle.co.uk or tell me during a session. I will normally respond to a rights request within one month, subject to any lawful extension or pause, and explain if one applies.

Enough contact, agreement and payment information is necessary to arrange and account for coaching. A callback number and current session location are required for my remote-session safety arrangements; without them I may need to postpone the session. An emergency contact, diagnosis and detailed health history are optional.

Questions and complaints

Raise a privacy concern or complaint at hello@drdarrelle.co.uk, by post to the address above, or through another usual contact method. Please say what concerns you and what would help. I will acknowledge a data protection complaint within 30 days, investigate without undue delay, keep you informed and explain the outcome.

You may complain to the Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/ or telephone 0303 123 1113. This does not remove other legal remedies.

I review this notice when the service or systems change and tell current clients about material changes before a new use of their information begins. You can request an accessible copy or explanation.

Enquiry Forms and Emails

I use your name, contact details and message to respond to your enquiry. This website is hosted by Squarespace, and form submissions are processed through Squarespace and Microsoft as the email provider. Please keep your message brief and avoid detailed health information or information identifying patients or colleagues. Read the Privacy Notice for details. This inbox is not an urgent support service.

Registration form and personal details

I use these details to arrange coaching and reconnect if a video call disconnects. Emergency contact details are optional. This form is processed through Squarespace and Microsoft as the email provider, client name and contact details are held on Squarespace. Please do not add diagnoses or medical history here. Read the Privacy Notice, including the information for emergency contacts. Any consent to use sensitive information for coaching is requested separately.

Invoices and payment requests

I use Squarespace or Stripe to issue invoices and process payments. They receive the details needed for these services. Please use the invoice number as your payment reference and avoid including diagnoses or other health information.

Cookies and website resources

Cookie notice

This website uses cookies and similar technologies to make requested features work and remember your privacy choices. Where enabled, optional analytics help me understand how the website is used. I ask for your choice before enabling optional technologies that require consent. You can accept, reject or change those choices through [insert working cookie settings link or control].

Essential technologies support functions such as security, remembering your choices and, where used, completing payment.

You can also control cookies in your browser; blocking essential cookies may affect some features. The Privacy Notice [link] explains how personal information is used and how to contact me.

Website resources

These resources provide general educational information and prompts for reflection. They cannot take account of your individual circumstances and do not provide a diagnosis, treatment, medical advice, occupational health assessment or crisis support. Use your own clinician or other relevant professional for individual advice. If you need immediate emergency assistance in the UK, call 999.

Coaching is an independent service and is separate from my NHS roles and NHS Practitioner Health. Viewing or downloading a resource does not create a coaching or clinical relationship.

Coaching agreement administration

Electronic acceptance and copies

We may accept this agreement electronically through Squarespace. I will provide a copy of the accepted agreement and the relevant booking details by email. Acceptance records are kept for administration and evidence of our agreement as explained in the Privacy Notice. Please contact me if you need an alternative accessible way to complete it.

My use of Squarespace does not change your statutory rights. Acceptance of this agreement is separate from any explicit consent to use sensitive personal information and any request to start a session during the cancellation period.

Fees and payment

The fee is agreed in advance and is inclusive of any applicable taxes. Payment is due the day of first session by online payment or bank transfer. Any additional service or charge requires our prior agreement. Payments and any refunds will be administered through the agreed payment method. I will not charge a separate surcharge for consumer card payment.

Sessions outside the UK

Sessions take place only when you are physically in the UK. Please tell me before a session if you will be elsewhere so that we can rearrange it under the booking changes policy. I will not deliver coaching while you are outside the UK.

Late cancellation and consumer rights

With less than 24 hours’ notice, a charge may apply for the reserved session, up to the agreed session fee, reflecting my reasonable loss after allowing for saved costs and any replacement booking. I will consider emergencies and access needs fairly. This does not override your legal cancellation rights.