Information Security & Confidentiality Statement

Niamh Ramachandran Trading as RISING PATHWAYS COACHING

Public-facing summary of how Rising Pathways Coaching approaches information security

Business	Version	Effective Date	Contact
Niamh Ramachandran trading as Rising Pathways Coaching	1.0	5 September 2026	[email protected]

Rising Pathways Coaching takes confidentiality and information security seriously. This statement summarises the practical safeguards used to help protect business and client information. It should be read alongside the Privacy Notice and the relevant service agreement.

1. Secure business systems

Core business email, documents, online meetings and related administration are managed through business systems selected for secure and reliable use, including Microsoft 365. Digital products and free resources are delivered through Payhip, and the public website is hosted through Carrd.

2. Access protection

• strong, unique passwords are used for important business accounts;• multi-factor authentication or equivalent additional sign-in protection is used on key systems where supported;• access to client information is limited to what is needed to operate the business and deliver the agreed service; and• account recovery and security information is reviewed periodically.

3. Client sessions and recordings

Client coaching and mentoring sessions are not recorded. I do not use AI transcription during client sessions.This reduces unnecessary creation and storage of sensitive conversational data.

4. Data minimisation and storage

I aim to collect and retain only information that is reasonably needed for service delivery, administration, legal or tax obligations, complaints, insurance or other legitimate business purposes. Retention periods and categories of information are described more fully in the Privacy Notice.

5. Devices and software

Business devices and software are kept under appropriate access controls and are intended to be kept updated with security updates.Device-locking and other available security features are used to reduce the risk of unauthorised access if a device is lost or stolen.

6. Incident response and recovery

Rising Pathways Coaching maintains an internal Cyber Incident Response and Disaster Recovery Plan. Security incidents, suspected account compromise, loss of data or loss of system access are assessed and responded to promptly.Where a personal data breach occurs, it is handled in accordance with applicable data protection requirements and the Privacy Notice.

7. Confidentiality and professional supervision

Client information is treated as confidential subject to the relevant agreement, legal obligations and any safeguarding or serious risk considerations that may apply.Where professional coaching supervision is used, client material will be discussed in an appropriately anonymised way wherever reasonably possible.

8. Ongoing improvement

Information security measures are reviewed as the business, technology and risk environment change. Additional safeguards may be introduced where proportionate, including recognised cyber security certification or further technical controls.

9. Contact

Questions about privacy or information security can be sent to [email protected].

Version 1 | Date: 5 September 2026 | Review: at least annually and sooner after a significant change.