By business type

Refund Policy Generator for coaches

Written for session notes, intake forms, professional confidentiality and the advice-versus-information line.

Generate your refund policy Read the refund policy guide

For a practice selling packages and programmes, the refund policy is really a cancellation policy with money attached. The clauses that get used are the ones about part-completed packages and sessions cancelled at short notice.

Coaching, counselling and therapy practices hold some of the most sensitive records a small business will ever handle, usually in tools designed for something else - a booking app, a notes app and an email inbox. Session notes about mental health are special category data under GDPR and UK GDPR, needing an Article 9 condition rather than just a lawful basis.

Professional confidentiality runs alongside data protection rather than inside it. Membership bodies impose their own duties on record-keeping, supervision and disclosure, and those obligations survive independently of any privacy notice.

The second exposure is the content side. Practitioners publish extensively - blogs, newsletters, free guides, social posts - and the line between general information and personalised advice is exactly where a disclaimer does real work.

What a refund policy for a coaching or therapy practice has to cover

Statutory cancellation rights for distance and off-premises sales, including the fourteen-day right
How the right interacts with services already begun at the client’s request
Part-completed packages: what is refundable and how it is calculated
Late cancellation and no-show charges, with the notice period stated
What happens if you end the relationship, including referral and any refund

How a coaching or therapy practice actually moves personal data

Intake and assessment forms

Health history, presenting issues, medication and emergency contacts, collected before any therapeutic relationship exists.

Session notes

The most sensitive record in the practice, often held in a general-purpose notes app with no access control.

Booking and reminder systems

Appointment data reveals that a person is receiving a particular kind of care, which is itself health data.

Supervision records

Case discussion with a supervisor, usually pseudonymised but still traceable within a small practice.

Payment and insurance claims

Where a session is claimed through insurance, the claim links identity to a category of treatment.

Newsletter and content lists

Marketing to people who have disclosed a health concern requires particular care about segmentation.

Third parties the draft will ask you about

a booking platform such as Acuity or Cliniko · Stripe · Google Workspace or Microsoft 365 · a notes or practice-management app · Mailchimp · Zoom or a secure video platform

The rules that apply

Special category data

Health, including mental health, requires an Article 9 condition. Explicit consent or the health and social care condition are the usual routes, each with its own requirements.

Professional body requirements

Membership bodies set their own standards on record-keeping, retention, supervision and the circumstances in which confidentiality may be broken.

Confidentiality and its limits

Safeguarding disclosures and legal obligations override confidentiality, and clients should be told this before the first session rather than at the point of disclosure.

Supervision

Discussing cases in supervision is processing, and clients should know it happens even when identifying details are removed.

Advertising and testimonial rules

Several professional bodies restrict testimonials, and consumer protection rules apply to outcome claims regardless.

What the generated refund policy contains

The statutory right, stated separately
Consumer cancellation rights exist whatever your policy says, so they are set out first and your goodwill terms second.
Time limits and how they are counted
When the clock starts, whether it runs in calendar or working days, and what stops it.
Condition and evidence requirements
What state goods must come back in, and what proof of purchase you accept.
Who pays return postage
Split between faulty and change-of-mind returns, because the law treats them differently.
Refund method and timing
Original payment method, and the deadline you commit to once goods or notice are received.
Exclusions, stated lawfully
Perishables, personalised goods, unsealed hygiene items and downloaded digital content - the exclusions the law actually permits.

The practitioner document set

Identify and record the Article 9 condition
Before the first client, and revisit it if you start taking insurance work.
Move session notes into a system with access control
And set a retention period that matches your professional body’s guidance.
Put confidentiality limits in the contracting conversation
Safeguarding, legal obligation, and supervision - explained before the first session.
Check the video platform settings
Recording, transcription and cloud retention, all off unless deliberately used with consent.
Separate the marketing list from the client record
Different purpose, different basis, different system if possible.
Publish a disclaimer on published content
Distinguishing general information from a therapeutic relationship.

Where this usually goes wrong

Session notes in a general notes app

No access control, no retention rule, and usually synced to a personal account.

No Article 9 condition identified

A lawful basis alone does not permit processing health data.

Confidentiality limits explained only after a disclosure

The limits belong in the contracting conversation and in the privacy notice, before the first session.

Marketing segmented by presenting issue

Using a health disclosure to target content is processing special category data for a new purpose.

Video sessions on a consumer platform

Recording defaults, transcript features and account settings can retain far more than the practitioner realises.

No retention schedule for closed cases

Professional bodies usually set one; the practice usually does not follow it.

Frequently asked questions

Are therapy notes special category data?

Yes. Notes about mental or physical health are health data under GDPR and UK GDPR, requiring an Article 9 condition in addition to a lawful basis, and in the UK usually a Schedule 1 condition with an appropriate policy document.

Can I use a normal booking app for a therapy practice?

You can, if it offers access control, a retention setting and a processor agreement - and if you keep clinical notes out of free-text fields that everyone in the account can read.

Do I have to tell clients about supervision?

You should. Supervision is processing, and clients are entitled to know that their case may be discussed even where identifying details are removed.

How long should I keep client records?

Your professional body usually specifies a period, and it is often long - several years after the last session, and longer where the client was a minor. That guidance is the starting point, not general minimisation instincts.

Can I run a no-refunds policy?

Not against statutory rights. In the UK and EU a consumer’s cancellation and faulty-goods rights apply regardless of what your policy says, and advertising "no refunds" is itself treated as a misleading practice.

Do digital products have to be refundable?

The cancellation right can be waived for digital content, but only if the customer gave express consent to immediate delivery and acknowledged losing the right. That acknowledgement has to be captured at checkout, not assumed.

How long do I have to issue a refund?

In the UK and EU, within 14 days of receiving the goods back or of the customer proving they returned them. Card scheme rules and marketplace policies often impose something tighter.