The boundary, in writing, before anyone signs up.
This is the part most coaching and wellbeing platforms leave vague. We don't, because the moment HR can't answer "who sees what" with certainty, employees stop being honest with their coach, and the whole thing stops working.
Four roles. A different boundary for each one.
This is the exact access model, not a summary of it: the same one written into every corporate agreement.
- Their own coach, sessions and reflections
- Their programme stage and sessions remaining
- Their own matched clients only
- Company name, for context
- Who has joined, and sessions booked and attended per person
- Outcome figures once ≥5 people report
- Platform operations, billing, support
- Only accessed to resolve a support request
Every number below the 5-person floor shows "Not enough participants yet" instead of a figure, by design, not by accident.
The practical detail your DPO will ask for.
A summary of how Signal handles company and employee data. Happy to share the full DPA and subprocessor list as part of onboarding.
GDPR-aligned by design
We collect the minimum data needed to run your programme, with a clear lawful basis for each field, and handle access, export and deletion requests from employees directly.
Hosted in the EU
Production data and files are hosted on AWS in the EU (Ireland and Sweden). Video calls, calendars, email and payments are provided by named subprocessors, listed in your DPA.
Confidentiality by agreement, not just policy
Coaches work under confidentiality terms aligned with the ICF's own code. Session content, notes and messages are never shared with your organisation, in any form.
Retention, kept sensible
Employee data is retained only as long as needed to run your programme and meet our own legal obligations, then deleted or anonymised, with details available in the DPA.
DPA available on request
A Data Processing Agreement, covering exactly what's processed and why, is part of the standard onboarding pack for every corporate programme.
Subprocessors, listed
We use a small number of named subprocessors for hosting, video calls, calendars, email and payments, some based outside the EU. The list is shared on request and kept current.
What comes up in procurement.
Can we ever request a transcript or notes from a specific employee's sessions?
No, not even with the employee's own consent forwarded to us. Session content stays between the employee and their coach without exception; it's structurally separate from what your admin dashboard can show.
Where is our data actually stored?
On AWS in the EU (Ireland and Sweden). We can confirm this in writing as part of your DPA.
What happens to employee data if we end the contract?
When a programme ends, new sessions stop and employees keep read-only access to their own goals and notes for 90 days. After that, their link to your company and the programme's usage data are anonymised, in line with the retention terms in your DPA.
More questions? See the full FAQ or talk to us directly.
Want the DPA before you talk to us?
Ask for it on the call and we'll send it over, along with the subprocessor list.