Privacy Policy

Kevin Clarke Leadership Coaching, a trading name of Ascertain Group Limited

Last updated: 30 October 2026

1. Who we are

Kevin Clarke Leadership Coaching is a trading name of Ascertain Group Limited, a company registered in England and Wales (company number [17551033]) with its registered office at [6 Hembrow, Evegate, Station Road, Ashford, Kent, United Kingdom TN25 6SX]. Kevin Clarke is the sole director.

Ascertain Group Limited is the data controller for the personal data described in this policy. We are registered with the Information Commissioner’s Office (ICO) under registration number [ICO REGISTRATION NUMBER].

You can contact us at [kevin@ascertaingroup.co.uk] or by post at the address above.

2. What this policy covers

This policy explains how we collect and use personal data when you visit kevinclarkecoaching.com, contact us, book or attend a coaching session, make a payment, or subscribe to our communications. It applies to prospective and current clients, website visitors and anyone else who contacts us.

We provide coaching to individuals and organisations in the United Kingdom, the United States and South Africa. We handle personal data in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, and we take account of the laws that apply where you live (see section 11).

3. The personal data we collect

• Enquiries. Your name, email address, phone number, organisation and the content of your message.
• Bookings. Your name, email address, time zone and any answers you give when booking a session through our scheduling tool.
• Payments. Your name, email address, billing details and confirmation of payment. Card details are handled by our payment providers; we do not see or store your full card number.
• Coaching. Information you give us in our intake form and sessions, such as your contact details, role, employer, background, goals, challenges and development areas, together with our notes of sessions and any agreed actions.
• Session recordings. We record a session only if you have agreed to it in advance.
• Website use. Your IP address, browser and device type, pages visited and how you reached our site, collected through cookies and similar technologies (see section 12).
• Business records. Our emails and correspondence with you, contracts, invoices and accounting records.

We collect this data directly from you. We may occasionally receive your details from your employer or sponsor if they have asked us to coach you, in which case we will tell you.

4. Sensitive (special category) information

Some of what you choose to share in coaching can be sensitive. In particular, our coaching can include an optional faith-informed approach, and if you choose that approach, you may tell us about your religious beliefs. You may also tell us about your health or wellbeing when discussing your goals.

Under data protection law, information about religious beliefs and health is special category data. We will only collect and use it where you have given us your explicit consent, which you can do in our intake form or client agreement. You do not have to share this information, and you can choose a coaching approach that does not involve faith. You can withdraw your consent at any time by contacting us, and we will stop using that information, although this will not affect anything we have already done lawfully.

Coaching is not therapy or medical treatment, and we do not ask for health information that we do not need.

5. How we use your data and our lawful bases

• To respond to your enquiry and arrange a session. We do this because it is necessary to take steps at your request before entering into a contract, and in our legitimate interests in running our business.
• To provide coaching. This is necessary to perform our contract with you (or with your organisation).
• To take payment, issue invoices and keep accounts. This is necessary for our contract with you and to comply with our legal obligations, including tax and accounting law.
• To handle special category information. We rely on your explicit consent (see section 4).
• To send newsletters or marketing. We rely on your consent, or, for existing clients, on our legitimate interest in telling you about similar services, which you can opt out of at any time. Every message includes an unsubscribe link.
• To run analytics and non-essential cookies. We rely on your consent.
• To keep our website secure and prevent spam or fraud. We rely on our legitimate interests.
• To maintain professional standards and defend legal claims. This includes supervision, insurance and accreditation requirements. We rely on our legitimate interests, and on your consent where we use client material that identifies you.

6. Confidentiality in coaching

What you tell us in coaching is confidential. We will only share it outside our practice in these circumstances:

• you have given your consent, for example for a recorded session to be used for accreditation or mentor coaching;
• we are legally required to do so, or the law permits us to do so to protect someone;
• we reasonably believe there is a serious risk of harm to you or to someone else; or
• we need to share it with our professional advisers or insurers to obtain advice or defend a claim.

Where we discuss our work in supervision or professional development, we anonymise it so that you cannot be identified, unless you have agreed otherwise.

If your organisation is paying for coaching, we will agree with you and the organisation in advance what, if anything, is reported back. We will not share the content of your sessions with your employer without your consent.

7. Who we share your data with

We do not sell your personal data. We share it only with organisations that help us run our practice, and only as far as necessary. These include:

• website hosting and business email providers (Hostinger);
• payment and banking providers (Revolut Merchant)
• accounting software providers (QuickBooks, provided by Intuit)
• video conferencing, document storage and form providers (Zoom, Microsoft OneDrive, Hostinger)
• our accountants, insurers, legal advisers and other professional advisers;
• HMRC, regulators or law enforcement where we are required to do so by law.

These providers act on our instructions under written terms, or as independent controllers of the data they need for their own legal obligations, such as fraud prevention.

8. Transfers outside the UK

Some of our providers are based outside the UK, including in the United States, and we also coach clients in the United States and South Africa. Where we transfer personal data to a country that does not have a UK adequacy decision, we use an approved safeguard, such as the UK–US Data Bridge where the provider is certified, or the ICO’s International Data Transfer Agreement or UK Addendum to standard contractual clauses. You can contact us for more information about the safeguards we use.

9. How long we keep your data

• Enquiries that do not lead to coaching: [12 months] from our last contact.
• Client records and session notes: [6 years] after our coaching relationship ends, which allows us to deal with any claims and meet our professional obligations.
• Invoices and accounting records: at least 6 years, as required by UK tax law.
• Session recordings/transcripts: [12 months] after our coaching relationship ends, which allows us to deal with any claims and meet our professional obligations.
• Newsletter subscriptions: until you unsubscribe.
• Website analytics data: [26 months] or as set out in our cookie information.

When the retention period ends, we delete or anonymise the data.

10. Your rights

Under the UK GDPR you have the right to:

• be informed about how we use your data;
• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data erased in certain circumstances;
• restrict how we use your data in certain circumstances;
• receive your data in a portable format;
• object to us using your data based on our legitimate interests, and to direct marketing at any time;
• withdraw your consent at any time where we rely on it; and
• not be subject to decisions based solely on automated processing. We do not make decisions about you in this way.

To use any of these rights, email [kevin@ascertaingroup.co.uk]. We will respond within one month. We may ask you to confirm your identity first.

If you are unhappy with how we have handled your data, please contact us first so we can try to put it right. You also have the right to complain to the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113.

11. Clients outside the UK

South Africa. If you are in South Africa, the Protection of Personal Information Act (POPIA) gives you rights similar to those above, and you may complain to the Information Regulator of South Africa.

United States and elsewhere. Depending on where you live, you may have additional privacy rights under local law, such as state privacy laws. If you would like to exercise any such rights, contact us and we will consider your request under the law that applies to you.

12. Security

We use appropriate technical and organisational measures to protect your data, including access controls, secure cloud services and encrypted connections. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If a breach affects your rights and freedoms, we will notify you and the ICO as the law requires.

13. Children

Our services are for adults. We do not knowingly collect personal data from anyone under 18.

14. Links to other websites

Our website may link to other sites, such as LinkedIn. We are not responsible for their privacy practices, so please read their policies before sharing your data.

15. Changes to this policy

We may update this policy from time to time. The latest version will always be on this page, with the date at the top. If we make a significant change, we will take reasonable steps to let you know.

16. Contact us

Ascertain Group Limited, trading as Kevin Clarke Leadership Coaching [6 Hembrow, Evegate, Station Road, Ashford, Kent, United Kingdom TN25 6SX] [kevin@ascertaingroup.co.uk]