Privacy Policy
CESURA PRIVACY POLICY NOTICE:
This Privacy Policy revised October 28, 2025
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ICO Reference C1512486
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Introduction
Cesura collects and uses personal data only as it might be needed for us to communicate with you about your appointments and to record simple notes about what is discussed and agreed in sessions. This information remains secure and confidential and will not be shared with any individual or organisation with the following exceptions:
Information may be shared if you, the client, specifically and in writing request that it is shared
Information may be shared if required by and legally demanded by the Courts of Justice of England
In addition, anonymous information about specific client cases may be discussed with a coaching supervisor in the course of coach supervision or continuing professional development. In those instances, the information is not attributable to any client and no written record that can be traced to an individual client is kept.
If at any time you have questions about our practices or any of your rights described below, you may reach our Data Protection Officer (“DPO”) by contacting us at stephenpaul@cesura.co.uk.
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Use of AI Note-Taking Tools in Online Sessions
Cesura occasionally uses Zoom’s AI Companion or similar automated tools to generate meeting notes or summaries for internal use. These tools may process audio, video, and text data from online sessions to create written summaries that support accurate record-keeping and client follow-up.
Use of these tools is subject to the following GDPR-compliant principles:
Lawful basis: Processing is based on explicit consent from clients. AI note-taking is only enabled when all participants agree to it.
Transparency: Clients are informed before the start of any session that uses AI note-taking, including what data is processed (audio, text, meeting metadata) and how it will be used.
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Purpose limitation: Data is used solely to generate meeting notes for the purpose of supporting coaching work and is not used to train or improve AI models.
Data storage and access: Any summaries generated are stored securely and treated as confidential client notes. Audio or transcript data processed by Zoom’s AI Companion is managed according to Zoom’s Privacy Statement
and is not shared with third parties for model training.
Retention: AI-generated notes are kept for the same period as standard session notes (normally three years after coaching ends) and are then securely deleted.
Participant rights: Clients may decline the use of AI note-taking tools or withdraw consent at any time. If consent is withdrawn, AI features will be disabled for that session.
Cesura ensures that any AI processing of personal data remains fully compliant with the UK GDPR, including Articles 5 (lawfulness, fairness, transparency), 6 (lawful basis for processing), and 32 (security of processing).
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What information do we collect?
We collect information so that we can communicate with you and continue to provide the services which are covered by our coaching agreement. Much of what may be considered to be personal data is collected directly from you when you:
Make initial contact to request a callback or to request an initial consultation
Complete and sign a client coaching agreement
This information typically includes:
Name
Address
Telephone number
Date of birth
Email address
Skype ID
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Additional information is specifically collected when you:
Communicate through email or text (SMS) message to request, confirm, change, or cancel an appointment
Communicate through email or text (SMS) message to give or receive coaching-related personal information that relates to or is in addition to, or is separate from, information shared verbally in a coaching session
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Information is also recorded when:
You arrange to pay by bank transfer – bank details, reference, and payment amount
When your coach raises an invoice payment
Finally, information is created when:
Notes are made by your coach during a coaching session – these are usually handwritten and not stored digitally/electronically. In exceptional cases, you may specifically request, in writing, that your coach passes information to a third party – such as an insurance company, employer, or other therapist.
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Cookies and similar technologies, including Google Analytics tracking code on our website, allow us to track browsing behaviour on the Cesura.co.uk website and look at anonymous aggregated data about how the website is used.
How you can access, update or delete your data
To access, view, update, delete, or port your personal data that we hold, please make a request in writing to:
Stephen Paul
Cesura // Coaching – Consulting
2 Somerset Road
Tunbridge Wells
TN4 9PX
Or by email to: stephenpaul@cesura.co.uk
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Please state how you would like to receive this information. We will acknowledge the request within 15 working days (Monday to Friday) and will provide the data within 30 working days. If you make a request to delete your personal data and that data is necessary for regular communication – appointment dates and times etc. – we may no longer be able to continue providing coaching services to you.
How we secure, store, and retain your data
Electronically held data is stored on a personal computer which is backed up to a cloud storage system. It is protected by the computer startup login security and the individual application security which includes: Google Mail, Microsoft Word, and Adobe PDF.
Please note: Email messages typically reside on various servers even after all parties have deleted the messages. Therefore, email should not be considered a secure form of communication. Confidentiality in an email message cannot be guaranteed.
We retain personal data only for as long as necessary to provide the coaching services you have requested and thereafter for a variety of legitimate legal or business purposes. When a client ceases to use our services, records are kept for three years to allow post-contractual data requests to be fulfilled and thereafter are deleted.
If you have any questions about the security or retention of your personal data, you can contact us at stephenpaul@cesura.co.uk.