Privacy Policy
ELEVEN26 works with people on matters that are personal and often commercially sensitive. This policy explains what we collect, how we handle it, and the rights you have under Australian privacy law.
We collect only what we need to work with you. We do not sell or share your information. Coaching conversations are confidential and are not reported to your employer or board without your written consent.
We may record a session or use AI tools to help consolidate notes — but only with your consent, and never to make decisions about you. You can ask us at any time what we hold, have it corrected, or ask us to delete it.
1. Who we are
This policy applies to ELEVEN26 (McArthur Strategic Pty Ltd, ABN 16 622 459 312), of Tasmania, Australia — referred to below as “we”, “us” or “ELEVEN26”. We provide coaching, executive leadership and organisational development services to individuals, leaders and organisations.
We handle personal information in accordance with the Privacy Act 1988 (Cth) and the thirteen Australian Privacy Principles (APPs). Where a small business is not automatically bound by the Privacy Act, we have chosen to conduct ourselves in line with the APPs regardless, because of the sensitivity of the work.
2. What we collect
We collect only information that is reasonably necessary to provide our services:
Name, email address, phone number, organisation and role; correspondence with us; and records of scheduling, invoices and payments.
Notes, goals, reflections, assessment or diagnostic results, and anything you choose to share in a session or between sessions.
Coaching conversations can touch on health, wellbeing or personal circumstances. Under the APPs this is “sensitive information” and we collect it only with your consent and only where it is relevant to the work.
If you submit our contact form we receive what you type into it. Our website does not use advertising or tracking cookies. Our hosting provider may keep standard server logs, including IP addresses, for security purposes.
You are not required to give us any of this information, but without it we may not be able to provide the service. You may deal with us anonymously or under a pseudonym for a general enquiry.
3. Why we collect it
- To provide coaching, facilitation and organisational development services.
- To arrange sessions, correspond with you and issue invoices.
- To keep engagement records so our work with you has continuity.
- To meet our legal, insurance and record-keeping obligations.
- To send you material you have asked to receive. We do not add you to any mailing list without your consent, and every email includes an unsubscribe option.
4. Confidentiality where an organisation is paying
Where an employer or board engages us to coach you, our duty of confidentiality is to you as the client. We do not report the content of coaching conversations to the sponsoring organisation.
With the sponsor we share only administrative matters — that sessions occurred, attendance, and progress against agreed goals at a general level — and only where that has been agreed at the outset. Anything more specific requires your written consent. In team and organisational work, individual contributions are reported in aggregated or de-identified form unless you agree otherwise.
5. When we may disclose information
We do not sell, rent or trade personal information. We disclose it only:
- with your consent;
- to service providers who help us operate — for example email, file storage, scheduling, video conferencing, accounting and payment providers — who are bound to protect it and use it only for that purpose;
- to our professional advisers, insurers or coaching supervisor, in de-identified form wherever practicable;
- where required or authorised by law, or where we reasonably believe disclosure is necessary to prevent a serious and imminent threat to someone's life, health or safety.
If disclosure of that last kind is ever necessary, we will tell you wherever it is safe and lawful to do so.
6. Recordings and use of AI tools
From time to time we may record a session, or use artificial intelligence tools to transcribe a recording and help consolidate notes, themes and agreed actions. This is to keep an accurate record and to save time — not to analyse or assess you.
We will not record a conversation without telling you beforehand and obtaining your consent. Consent is entirely optional, can be given for one session only, and can be withdrawn at any time — including part way through a session, in which case recording stops immediately.
In team or workshop settings, everyone present is told before recording begins and any participant may decline. If anyone declines, we do not record.
We use reputable business-grade transcription and summarisation services under paid agreements that prohibit the provider from using your content to train their models. We do not paste identifiable session content into free or consumer AI tools.
AI output is a draft only. Zach reviews and edits every summary before it is used or shared, and no decision, assessment or recommendation about you is ever made by an automated tool.
Audio and video recordings are deleted once the summary has been finalised, and in any case within thirty days, unless you ask us to keep them for longer. The edited written summary is then retained as part of your engagement record under section 8 below.
Recordings, transcripts and AI-assisted summaries are treated exactly as any other session material. They are not provided to a sponsoring employer or board, and section 5 above continues to apply.
You may ask for a copy of any recording or summary that relates to you, or ask us to delete it, at any time.
7. Storage, security and overseas providers
Information is held in reputable cloud services with access limited to those who need it, protected by device encryption, strong authentication and multi-factor authentication where available. Session notes are kept separately from administrative records.
Some of our providers store data outside Australia, including in the United States and the European Union. Where that occurs we take reasonable steps to ensure the provider handles your information in a way consistent with the APPs.
8. How long we keep it
We keep engagement records for seven years after our work together ends, consistent with tax, insurance and professional record-keeping expectations, then destroy or de-identify them. If you ask us to delete your information sooner we will do so, unless we are required by law to retain it.
9. Access and correction
You may ask us for a copy of the personal information we hold about you, and ask us to correct anything inaccurate or out of date. Email the address below. We will respond within thirty days and will not charge for a straightforward request. If we cannot give access — for example where it would unreasonably affect another person's privacy — we will explain why in writing.
10. Data breaches
If a breach occurs that is likely to result in serious harm, we will act in accordance with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988 (Cth): we will notify affected individuals and the Office of the Australian Information Commissioner as soon as practicable, and set out what happened and what to do about it.
11. Complaints
If you believe we have mishandled your personal information, contact us first — most concerns are resolved quickly. We will acknowledge your complaint within five business days and respond substantively within thirty days.
If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC): oaic.gov.au, 1300 363 992, or GPO Box 5288, Sydney NSW 2001.
12. Changes to this policy
We may update this policy as our practices or the law change. The current version is always published on this page with the date it was last updated. Material changes affecting existing clients will be communicated directly.
How we work together, including fees, scheduling and confidentiality in practice, is set out in our Terms of Engagement.
This policy is provided as general information and reflects how ELEVEN26 handles personal information. It is not legal advice and has not been reviewed by a lawyer. Before publishing, have it checked against your actual systems, providers and insurance obligations.
