AI Policy

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Last Updated: 23 October 2025

1. Introduction

At Oceanus Leadership Development ("we," "our," or "us"), we are committed to transparency regarding our use of artificial intelligence (AI) tools and technologies in our coaching services. This AI Policy explains how we use AI, how our clients may use AI during our engagement, and the responsibilities of all parties in ensuring data protection and confidentiality.

This policy should be read in conjunction with our Privacy Policy and Client Agreement.

2. Our Use of AI

2.1 How We Use AI

We may use AI tools to support the delivery and administration of our coaching services in the following ways:

· Administrative Support: AI tools may be used for scheduling, email drafting, document preparation, and other administrative tasks

· Content Development: AI may assist in creating coaching materials, frameworks, worksheets, and resources

· Research and Insights: AI tools may help us stay current with leadership trends, research, and best practices

· Session Preparation: AI may assist in preparing for coaching sessions, including reviewing themes and developing coaching questions

2.2 What We Do NOT Use AI For

We do not use AI for:

· Recording or transcribing coaching sessions(we do not use AI notetakers or similar tools)

· Making coaching decisions or providing coaching advice on our behalf

· Analysing client personal data without explicit consent

· Storing detailed session content or confidential client information

2.3 Data Protection in Our AI Use

When we use AI tools:

· We anonymize or pseudonymize any client information before inputting it into AI systems

· We remove all personally identifiable information (names, organizations, specific details)

· We use generic scenarios and hypothetical situations rather than actual client cases

· We comply with GDPR and UK data protection law in all AI-assisted activities

· We only use AI tools from reputable providerswith appropriate data protection measures

3. Client Use of AI

3.1 AI Notetakers and Recording Tools

We understand that some clients may wish to use AI-powered notetakers, transcription services, or recording tools during coaching sessions. If you wish to use such tools:

You MUST:

1. Obtain explicit consent from the coach before any recording or AI notetaker is activated

2. Request permission in advance of each session (blanket consent for all sessions is not assumed)

3. Inform the coach which specific AI tool or service you intend to use

4. Ensure compliance with your organization's data protection and IT policies

5. Take responsibility for the security and confidentiality of any recordings or transcripts

6. Delete or securely store recordings in accordance with data protection requirements

We reserve the right to:

· Decline consent for recording or AI notetaker use

· Request that certain topics or discussions are not recorded

· Terminate the use of AI tools during a session if concerns arise

3.2 Client Use of AI for Coaching-Related Work

Clients are welcome to use AI tools to support their development work (e.g., drafting documents, researching topics, preparing for sessions). When doing so:

· Do not share confidential coaching discussions or personal insights with AI tools without considering privacy implications

· Be mindful that AI-generated content should be reviewed and personalized rather than used verbatim

· Ensure any use of AI complies with your organization's policies

· Remember that AI cannot replace the personal reflection and self-awareness central to coaching

4. Data Protection and GDPR Compliance

4.1 Legal Basis for Processing

When AI is used in connection with coaching services:

· Processing is based on legitimate interests(providing and improving coaching services) and/or consent where required

· Clients have the right to object to AI-assisted processing of their personal data

· All processing complies with GDPR, UK GDPR, and Data Protection Act 2018

4.2 Data Subject Rights

Clients retain all rights under data protection law, including:

· Right to access: Request information about how AI has been used with your data

· Right to erasure: Request deletion of any data processed through AI tools

· Right to object: Object to the use of AI in processing your personal data

· Right to restriction: Request limitations on AI-assisted processing

4.3 Third-Party AI Processors

When we use third-party AI tools, we ensure:

· Data Processing Agreements are in place with AI service providers

· Providers are GDPR-compliant and have appropriate security measures

· Data is processed within the UK/EEA where possible, or with appropriate safeguards for international transfers

· Providers do not use client data to train their AI models (where this can be controlled)

4.4 Data Retention

· AI-generated content related to client work is retained only as long as necessary

· Clients may request deletion of any AI-processed information at any time

· We conduct regular reviews of data held in or processed by AI systems

5. Confidentiality and AI

5.1 Our Commitment

All coaching conversations remain strictly confidential, whether or not AI tools are used for administrative purposes. Our confidentiality obligations are not diminished by the use of AI for anonymized, non-specific support.

5.2 Client Responsibilities

If you use AI tools (including notetakers) during or in connection with coaching:

· You are responsible for maintaining confidentiality of session content

· You must ensure your AI tool provider has adequate security and privacy protections

· You should not share recordings or transcripts that could identify others without consent

· You remain accountable for how coaching content is used, shared, or stored

6. Quality and Accuracy

6.1 AI Limitations

We acknowledge that AI tools:

· May produce inaccurate, biased, or incomplete information

· Cannot replace human judgment, intuition, and coaching expertise

· Should be used as a supplementary tool, not a primary decision-maker

6.2 Our Standards

· All AI-generated content is reviewed and edited by qualified professionals

· Coaching advice and insights come from human expertise, not AI generation

· We maintain professional standards and ethical guidelines regardless of tools used

7. Transparency and Disclosure

We are committed to transparency about AI use:

· We will inform clients if AI has been used in a way that materially affects their coaching experience

· We are open to discussing our AI practices with clients

· We welcome questions and concerns about AI use

8. Changes to This Policy

We may update this AI Policy periodically to reflect:

· Changes in our AI practices

· New legal or regulatory requirements

· Developments in AI technology

· Client feedback and best practice evolution

We will notify clients of material changes and post the updated policy on our website.

9. Questions and Concerns

If you have questions about our use of AI, wish to exercise your data protection rights, or have concerns about AI in your coaching engagement, please contact:

Oceanus Leadership Development
Email: rachel@oceanus-leadership.co.uk
Phone: +44 (0) 7879 411418

9. Compliance

This policy is designed to comply with:

· General Data Protection Regulation (GDPR)

· UK GDPR and Data Protection Act 2018

· Information Commissioner's Office (ICO) guidance on AI and data protection

· Professional coaching ethics and standards

We are committed to responsible, transparent, and secure use of AI in all our professional activities.

This AI Policy is effective as of the date stated above and applies to all coaching services provided by Oceanus Leadership Development.