PT Client Privacy Notice (template)
A starting point for the privacy notice you give to your clients.
Read this first. This is a template, not legal advice. As the controller of the personal data you collect about your clients, you are responsible for the privacy notice you actually give them. You should review and adapt this wording for your own practice, and you should consider taking advice from a UK solicitor or the Information Commissioner's Office (ICO) before relying on it.
Wording in [square brackets] needs to be filled in with your details before you publish or send the notice.
Download as a Word document. Easier to edit and rebrand for your own use.
How to use this template
- Download the Word version using the button above, or copy and adapt the wording below.
- Fill in every [bracketed] placeholder with your details.
- Review the lawful basis section and confirm it matches your actual practice. If you rely on a different basis (for example, legitimate interests rather than contract), update that section.
- Decide how you will give the notice to clients. Common options: include it in your onboarding pack, publish it on your website, or email it before adding them to the platform.
- Keep a dated copy of the version each client received. If you change the wording in a material way, give clients an updated version.
This template assumes the standard 141kg setup: you use the platform as a personal trainer to record client training, and 141kg Ltd acts as your processor under the Data Processing Agreement at https://legal.141kg.com/dpa/.
The template
Who I am and what this notice is about
I am [your name or trading name], a personal trainer based in [your town or city]. This notice explains what personal data I collect about you as my client, why I collect it, how long I keep it, and the rights you have under UK GDPR.
I am the controller of the personal data I collect about you for personal training and coaching purposes. 141kg Ltd provides the software platform I use to record and manage your training data. They act as my processor for that data under a Data Processing Agreement.
You can contact me about anything in this notice at [your email], or by phone on [your phone number, optional].
What I collect
I collect the following categories of personal data about you:
- Identification and contact data: your name, email address, and date of birth.
- Background data (optional): your sex, where you choose to provide it for benchmarking inside my training system.
- Training data: the workouts I plan for you, the sets, reps, weights, times, and exercises you complete, session dates and times, my notes about your sessions, and any goals we agree on.
- Health data: where you have given explicit consent, I may also record your body weight, heart rate during sessions, perceived effort (RPE) on a 0 to 10 scale, and an estimate of session calories. This category is treated as special category health data under UK GDPR Article 9.
What I do not collect on the 141kg platform
The 141kg platform is a training record. It is not a clinical record system. I do not record the following on it:
- Injuries, conditions, medications, surgeries, allergies, or other medical history.
- PAR-Q or health screening questionnaire responses.
- Progress photos or body composition images.
- Mental health information.
[Optional, if applicable: If I need to record information about your health history for safety reasons, I keep it in [describe your separate system, for example a paper consultation form locked in my office, or a separate encrypted document store], not on the 141kg platform.]
Why I collect this data and my lawful basis
I use your personal data to provide personal training and coaching services to you. That includes planning your training, recording what we do in each session, tracking your progress, communicating with you about your training, and managing the safety and effectiveness of your programme.
My lawful basis for processing your data under UK GDPR Article 6 is performance of a contract with you (Article 6(1)(b)). I cannot deliver the training service we have agreed without recording your training data.
Where I record health data (body weight, heart rate, RPE, session calories), my lawful basis under Article 9 is your explicit consent (Article 9(2)(a)). You give this consent in the Client app when you first set up your account on the 141kg platform. You can withdraw it at any time in the app or by contacting me; withdrawal does not affect any processing carried out before the withdrawal.
Who I share your data with
I share your data with the following:
- 141kg Ltd, who provides the software platform I use to record your training. They are my processor. They process your data on my behalf, on documented instructions, under their Data Processing Agreement at https://legal.141kg.com/dpa/. Their Privacy Notice is at https://legal.141kg.com/privacy/.
- [Add any other organisations you share data with, for example: a separate accounting system; a separate scheduling/booking system; a partner gym; an insurance provider. If you do not share data with anyone else, replace this line with: "I do not share your data with anyone else."]
I do not sell your data and I do not share it for marketing without your separate consent.
Leaderboard
The 141kg platform includes an optional leaderboard. If I turn it on, your training activity produces a score that ranks you against my other clients. Those clients can see your position, your score, and your display name. They cannot see your contact details, date of birth, body measurements, or session notes.
Ask me to leave you off the leaderboard at any time, and I can switch you off.
Usage analytics on the 141kg platform
Separately from the training data I record about you, the 141kg platform records some analytics about how the app is used: when you open it, which screens you open, and that you used certain actions, including logging a set, a body weight, an RPE, or a heart rate or calorie figure. These record that an action happened and when, not the value behind it.
For this usage analytics, 141kg is the controller, not me. They analyse it only in aggregate, across all users of the platform, and apply a small-number floor that drops anything used by fewer than three people on a given day, so nothing they look at can single you out. It is not used for advertising or profiling. I never see these events. The one thing I can see, the date you last used the app, comes from your login record and not from this analytics. See the next section. The full detail, including the lawful basis and how long it is kept, is in 141kg's Privacy Notice at https://legal.141kg.com/privacy/.
What I can see about your app use, and emails I might send you
The 141kg platform shows me the date you last used the app, taken from your login record. That is all I see: one date. I do not see which screens you opened, how long you stayed, or any history of how you used the app.
If you have never signed in, or if you have been away for a while, I may ask 141kg to send you an email on my behalf reminding you about the app. I choose who to email. 141kg sends none of these on their own initiative. The email tells you about the app and shows example screens. It carries none of your training data.
Every one of these emails has an unsubscribe link. Using it stops all of them, and I cannot undo it. You can also just tell me to stop, and I will. Opting out changes nothing else about your training or your account.
I am the controller for this and the sender of the email. My lawful basis is [choose one: your consent, which you gave when you agreed to receive emails from me; or my legitimate interest in keeping you engaged with the training service you have bought from me, relying on the soft opt-in in regulation 22(3) of the Privacy and Electronic Communications Regulations 2003]. Either way, you can opt out at any time.
How long I keep your data
I keep your training records while you remain my client. After you stop training with me, I keep your records for [choose a period, for example "12 months", "the remainder of the current tax year plus 6 years", or "until you ask me to delete them"]. I keep records I am required to keep by law (for example, accounting records) for the period that law requires, typically 6 years.
Your UK GDPR rights
You have the following rights over the data I hold about you:
- Access: ask me for a copy of the data I hold about you.
- Rectification: ask me to correct data that is inaccurate or incomplete.
- Erasure: ask me to delete your data, subject to any records I am required to keep by law.
- Restriction: ask me to stop processing your data while we sort out a complaint or correction.
- Portability: ask me for your data in a machine-readable format. The 141kg platform provides an export tool I can use to give you this, and you can also download your own data directly from the Client app.
- Object: object to processing I carry out on the basis of legitimate interests, where applicable.
- Withdraw consent: where I rely on your consent (for health data), withdraw it at any time.
- Complain: if you are not happy with how I handle your data, you can complain to the UK Information Commissioner's Office at ico.org.uk. I would prefer you contact me first so I can put things right.
To exercise any of these rights, contact me at [your email].
Changes to this notice
If I make a material change to this notice, I will give you the updated version and the date it takes effect.
Contact
For anything about this notice, contact me at [your email].
This notice is based on the 141kg PT Client Privacy Notice template version 2026-07-12-b. The template is a starting point and not legal advice.