top of page

Intentional Steps Ltd - Policies

Intentional Steps Ltd

Data Protection Policy

Reviewed and updated for 2026 · UK GDPR and Data Protection Act 2018
 

1. Introduction
Intentional Steps Ltd is committed to protecting the privacy and security of personal data. This Data Protection Policy explains how we collect, use, store, and safeguard personal data in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
 

2. Scope
This policy applies to all personal data collected, processed, and stored by Intentional Steps Ltd, whether that data relates to clients, coaching participants, employees, contractors, or other individuals.
 

3. Data We Collect
We may collect the following types of data:

  • Full Name

  • Contact Information (email, phone number, address)

  • Job Title and Organisation

  • Session Notes (where applicable)

  • Feedback and Testimonials (with permission)

  • Payment Details, including invoicing and billing records held in Xero and QuickBooks

  • Client Relationship and Enquiry Data held in Dubsado (e.g. onboarding forms, contracts, scheduling information)

  • Any other information voluntarily provided during coaching, training, or programme participation
     

4. Purpose of Data Collection
We only collect personal data necessary to:

  • Deliver coaching, training, and supervision services

  • Manage client relationships and communications, including via our client management system, Dubsado

  • Process payments and invoices through our accounting systems, Xero and QuickBooks

  • Evaluate and improve our services

  • Fulfil legal or regulatory obligations (e.g., record-keeping for professional accreditation)
     

5. Legal Basis for Processing
We process personal data on one or more of the following legal bases:

  • Consent: When you provide explicit consent for particular processing (e.g., testimonials).

  • Contractual necessity: When data is necessary to deliver our services.

  • Legal obligation: Where processing is required to comply with laws or regulations, including financial record-keeping obligations.

  • Legitimate interest: Where processing is necessary for our legitimate business interests and does not override your rights.
     

6. Data Storage and Security
Personal data is stored securely using encrypted digital systems, including our client management platform, Dubsado, and our accounting platforms, Xero and QuickBooks.

  • Access is restricted to authorised personnel only.

  • Dubsado, Xero and QuickBooks are used under our contracts with those providers, each of which maintains its own security and data processing standards as a data processor acting on our instructions.

  • Data is retained only for as long as necessary to fulfil the purpose for which it was collected, or to meet legal, regulatory, or professional obligations.

  • We periodically review our third-party systems, including Dubsado, Xero and QuickBooks, to confirm they continue to meet UK GDPR requirements.
     

7. Sharing Personal Data
We will never sell or share your personal data for marketing purposes. Personal data may only be shared when:

  • Required to deliver agreed services (e.g., working with associate coaches, or processing through our systems Dubsado, Xero and QuickBooks)

  • Required by law, regulation, or professional accreditation body

  • With your explicit consent (e.g., publishing testimonials)

Where personal data is processed by third-party platforms such as Dubsado, Xero and QuickBooks, those providers act as data processors and are bound by their own data protection and security obligations.
 

8. Your Rights
Under UK GDPR, you have the following rights:

  • Access: You can request a copy of the personal data we hold about you.

  • Rectification: You can request correction of inaccurate or incomplete data.

  • Erasure: You can request deletion of data where appropriate.

  • Restriction: You can request to restrict processing in certain circumstances.

  • Objection: You can object to data processing based on legitimate interests.

  • Data Portability: You can request to receive your data in a structured format.

To exercise any of these rights, please contact info@intentionalsteps.co.uk.
 

9. Data Breaches
In the unlikely event of a data breach, including one affecting Dubsado, Xero, QuickBooks or any other system we use, we will follow our internal data breach response process. If required, we will notify affected individuals and the Information Commissioner's Office (ICO) within the statutory timeframe.
 

10. Changes to This Policy
This policy is reviewed regularly and updated as necessary to ensure compliance with data protection laws and best practice. It was last reviewed in 2026. The latest version will always be available at www.intentionalsteps.co.uk.
 

11. Contact Details
For questions or concerns about this policy or our data protection practices, please contact:
Crystal Small
Data Protection Lead
Intentional Steps Ltd
Email: info@intentionalsteps.co.uk

Intentional Steps Ltd

Code of Conduct

Reviewed and updated for 2026
 

1. Purpose
At Intentional Steps Ltd, we are committed to maintaining the highest professional standards across all our coaching, training, supervision, and consultancy services. This Code of Conduct outlines our expectations for professional behaviour and ethical practice.

​

2. Professionalism

  • Treat all clients, colleagues, and partners with respect and courtesy.

  • Uphold confidentiality in line with data protection laws and professional coaching standards, including in how client information is handled within Dubsado, Xero and QuickBooks, save where disclosure is required by law or a professional accreditation body.

  • Deliver services with integrity, honesty, and care.

  • Be punctual for all sessions, meetings, and engagements.
     

3. Boundaries

  • Maintain clear professional boundaries with all clients and avoid conflicts of interest.

  • Refrain from providing advice outside your area of competence.
     

4. Quality of Service

  • Continuously seek professional development and uphold coaching best practices.

  • Welcome constructive feedback and strive for continuous improvement.
     

5. Respect for Diversity

  • Embrace inclusivity, ensuring services are accessible to all regardless of background.

  • Challenge discriminatory behaviour or language when encountered.
     

6. Compliance

  • Adhere to all applicable laws, regulations, and ethical guidelines from professional bodies such as the ICF.
     

Intentional Steps Ltd

Equality and Diversity Policy

Reviewed and updated for 2026
 

1. Commitment Statement
Intentional Steps Ltd is committed to fostering an inclusive environment where everyone feels valued, respected, and able to participate fully. We believe diversity enriches our work, and we actively oppose discrimination of any kind.
 

2. Scope
This policy applies to all:

  • Clients

  • Associates and contractors

  • Suppliers

  • Event participants
     

3. Our Commitment
We do not tolerate discrimination based on:

  • Age

  • Disability

  • Gender identity or expression

  • Race or ethnicity

  • Religion or belief

  • Sexual orientation

  • Socio-economic background

  • Any other protected characteristic
     

4. Implementation

  • All services are designed to be inclusive and accessible.

  • Any discriminatory behaviour will be addressed swiftly.

  • We aim to continually review and improve our equality practices.
     

5. Reporting Concerns
Anyone who feels they have been treated unfairly can raise concerns via our Grievance Handling Policy.
 

Intentional Steps Ltd

Workplace Health and Safety Policy

Reviewed and updated for 2026
 

1. Purpose
While Intentional Steps Ltd delivers virtual services, we also participate in external events and may visit client offices. We are committed to ensuring the health, safety, and wellbeing of everyone we work with.
 

2. Virtual Working

  • Associates and employees are encouraged to create a safe and comfortable home workspace.

  • Regular breaks, ergonomic seating, and appropriate screen use are recommended.
     

3. External Events and Client Visits

  • We will assess health and safety conditions when attending exhibitions, conferences, or client sites.

  • All individuals representing Intentional Steps Ltd must comply with on-site health and safety rules.

  • Any hazards, accidents, or incidents must be reported immediately to the company director.
     

4. Mental Wellbeing

  • Intentional Steps Ltd recognises the importance of mental health alongside physical safety.

  • We encourage open dialogue about wellbeing and provide wellbeing support where possible.
     

Intentional Steps Ltd

Privacy Policy

Reviewed and updated for 2026
 

1. Introduction
Intentional Steps Ltd takes your privacy seriously. This Privacy Policy explains how we collect, use, and protect your personal data when delivering our services.
 

2. What Data We Collect
We may collect:

  • Contact details (name, email, phone)

  • Job title and organisation

  • Session notes and feedback

  • Client relationship, onboarding and scheduling information, held in Dubsado

  • Payment and invoicing information, held in Xero and QuickBooks

  • Any information you voluntarily provide during sessions or enquiries
     

3. How We Use Data

  • To deliver coaching, training, and supervision services

  • To manage communication, appointments and client relationships via Dubsado

  • To process payments and manage accounts via Xero and QuickBooks

  • To gather feedback and improve our services

  • To meet professional accreditation or regulatory requirements
     

4. Data Sharing
We do not sell or share your data for marketing. Data may be shared only:

  • With your explicit consent (e.g., testimonials)

  • To fulfil legal or regulatory obligations

  • With trusted associates working directly on your service delivery

  • With our third-party service providers, Dubsado, Xero and QuickBooks, who process data on our behalf as part of delivering our services
     

5. Data Security
We store data securely using encrypted systems, including Dubsado, Xero and QuickBooks, with access limited to authorised personnel only.
 

6. Your Rights
You have the right to:

  • Access your data

  • Request corrections

  • Request deletion (where lawful)

  • Withdraw consent where given
     

7. Contact
For data queries, email: info@intentionalsteps.co.uk
Full data protection policy can be viewed here: www.intentionalsteps.co.uk
 

Intentional Steps Ltd

Grievance Handling Policy

Reviewed and updated for 2026
 

1. Purpose
Intentional Steps Ltd is committed to maintaining positive and professional relationships with clients, associates, and partners. We aim to resolve any grievances quickly and fairly.
 

2. What is a Grievance?
A grievance is any concern, complaint, or dissatisfaction related to:

  • Service delivery

  • Conduct of associates or employees

  • Discrimination, harassment, or unfair treatment
     

3. Process
Step 1: Informal Discussion
In the first instance, we encourage you to raise your concern directly with the person involved, if appropriate.

Step 2: Formal Grievance
If unresolved, or if you prefer, you can submit a formal grievance by emailing: info@intentionalsteps.co.uk
Your grievance will be acknowledged within 3 working days and investigated thoroughly.

Step 3: Outcome and Resolution
We will aim to respond with a proposed resolution within 10 working days.
If you are unsatisfied with the resolution, an independent review may be offered.

4. Confidentiality

All grievances will be handled sensitively and confidentially, in line with data protection laws, except where disclosure is required by law, regulation, or a professional accreditation body, or where necessary to protect the safety of any individual.
 

5. Non-Retaliation
Raising a grievance will never result in unfair treatment or discrimination against you.

bottom of page