Reinvent Pathways Ltd - Customer Privacy Policy

This privacy notice explains how Reinvent Pathways Ltd (“we”, “us”, “our”) collects, uses, and protects your personal information, and your rights under UK data protection law.

Contact details

Email: sarah@reinventcoaching.com

What personal information we collect, use, and why

We collect and use personal information for the purposes set out below. The specific information collected depends on your relationship with us (for example, client, candidate, or business contact).

Personal information we may collect

  • Names and contact details

  • Addresses

  • Gender and pronoun preferences

  • Account and registration information

  • Payment details and transaction data

  • Purchase or service history

  • Marketing preferences

  • Website and usage information

  • Employment and professional information (such as employment history, role information, qualifications, and right to work information)

  • Records of meetings, decisions, correspondence, audio or video recordings (where relevant)

  • Information relating to queries, compliments, complaints, or claims

Special category information

Where necessary, we may process health and wellbeing information. This information is subject to additional protection and is handled with particular care.

How we use your information

We use personal information for the following purposes:

  • Providing and improving coaching and recruitment services

    To deliver services, understand client and candidate needs, assess suitability for roles or opportunities, communicate effectively, and improve service quality.

  • Client and customer account management

    To manage accounts, bookings, payments, security, and ongoing service relationships.

  • Communication and service administration

    To communicate about appointments, scheduling, availability, service delivery, and other day-to-day administrative matters.

  • Marketing and information updates

    To send relevant service updates and limited marketing communications where appropriate, and where required, with your consent.

  • Recruitment activities

    To assess candidates, manage recruitment processes, communicate with candidates and client organisations, and facilitate placements.

  • Protecting client welfare

    To identify and respond appropriately to wellbeing or safeguarding concerns, including situations involving vulnerability or risk.

  • Legal and regulatory compliance

    To meet legal, accounting, tax, regulatory, and professional obligations.

  • Queries, complaints, and claims

    To respond to enquiries, investigate complaints, manage disputes, and handle actual or potential legal claims.

Lawful bases and your data protection rights

Under UK GDPR, we must have a lawful basis for processing your personal information. Depending on the purpose, we rely on one or more of the following:

  • Contract – where processing is necessary to enter into or carry out a contract with you

  • Legal obligation – where processing is required to comply with the law

  • Legitimate interests – where processing is necessary for our business or professional interests and does not override your rights

  • Consent – where you have given clear permission

  • Vital interests – where processing is necessary to protect someone’s life or wellbeing in an emergency

Our legitimate interests include:

  • Delivering and improving coaching and recruitment services

  • Communicating effectively and administering services

  • Supporting recruitment and professional opportunities

  • Protecting client welfare and acting responsibly

  • Managing complaints, claims, and professional risk

We always balance our legitimate interests against your rights and expectations, apply data minimisation, and use appropriate safeguards.

Your data protection rights

You have the right to:

  • Access your personal information

  • Ask for inaccurate or incomplete information to be corrected

  • Request deletion of your information (where applicable)

  • Restrict or object to processing

  • Request data portability

  • Withdraw consent at any time (where consent is used)

Requests can be made using the contact details above. We will respond within one month.

Where we get personal information from

  • Directly from you

  • From publicly available sources, such as professional networking platforms, where relevant

How long we keep information

We retain personal information only for as long as necessary for the purposes for which it was collected, including service delivery, legal compliance, and resolving queries or claims.

Retention periods vary depending on the type of information. For example:

  • Client and candidate information is usually kept for the duration of the relationship and a limited period afterwards

  • Recruitment information is generally retained for up to 12 months after last contact

  • Financial and contractual records are kept for up to six years in line with legal requirements

Information is securely deleted or anonymised when no longer required.

Who we share information with

Data processors

We share personal information with trusted service providers who process data on our behalf, such as providers of:

  • Email and communication services

  • Scheduling and video conferencing

  • Secure cloud storage and document management

  • Payment processing, accounting, and invoicing

  • IT and systems support

These providers act only on our instructions and are subject to appropriate contractual and security obligations.

Other recipients

We may also share personal information with:

  • Insurance providers and brokers

  • Professional or legal advisers

  • Regulatory authorities

  • Emergency services (where necessary)

  • Organisations we are legally required to share information with

Sharing information outside the UK

Where necessary, personal information may be transferred outside the UK, including to the United States.

We use appropriate safeguards to protect international transfers, including the UK Addendum to the EU Standard Contractual Clauses (SCCs).

Our service providers that may receive data outside the UK include:

  • Google (email and storage services)

  • Calendly (scheduling services)

Further information about safeguards is available on request.

How to complain

If you have concerns about how we use your personal information, please contact us using the details above.

You may also complain to the Information Commissioner’s Office (ICO):

Helpline: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint

Last updated: 30th January 2026