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ADR-004: Embrace Therapy Territory

Status: Accepted Date: February 2026 Decision Maker: Jesse Torrence (Founder)

Context​

Enterprise coaching inevitably touches on personal, emotional, and mental health topics. Traditional coaching platforms either:

  1. Avoid it entirely: Block or redirect any mental health discussion (limiting coaching effectiveness)
  2. Ignore it: Process the data without special handling (compliance risk)
  3. Embrace it: Handle deep personal content as a first-class architectural concern

Jesse's explicit direction: "We need to lean head first into it and make it happen... once this is successful on the coaching market, I plan to migrate and move over into the therapy market as well more directly."

Decision​

Build the architecture to fully support deep personal, emotional, and mental health content from day one, with appropriate legal framing and technical safeguards.

This means:

  1. Data classification: Health-like data is treated as special category data (GDPR) with enhanced protections
  2. Consent flows: Explicit consent for processing sensitive personal data
  3. Escalation protocols: AI-driven crisis detection and human handoff
  4. Legal framing: "Coaching with deep personal development support" — not therapy (until licensed)
  5. Architecture ready: "Regulated data mode" with separate encrypted storage, field-level encryption
  6. Future therapy migration: Architecture designed to support eventual HIPAA/clinical requirements

Alternatives Considered​

Alternative 1: Avoid Therapy Territory​

  • Pro: Lower regulatory risk, simpler architecture, no special category data concerns
  • Con: Coaching becomes superficial and meaningless; loses competitive advantage; doesn't match how real coaching works
  • Rejected because: "Any good coaching really will do that... if not, you're not really offering anything meaningful" (Jesse)

Alternative 2: Handle It But Don't Architecture For It​

  • Pro: Cheaper to build initially
  • Con: Technical debt when therapy market expansion happens; data handling vulnerabilities if sensitive content isn't specifically protected
  • Rejected because: Retrofitting security for sensitive data is harder and riskier than building it in from the start

Consequences​

Positive​

  • Competitive moat: Most coaching platforms avoid this space
  • Better coaching outcomes: Coaches can work with the full range of human experience
  • Therapy market readiness: Architecture supports eventual clinical use
  • Honest product positioning: Doesn't pretend coaching doesn't involve emotional content

Negative​

  • Higher compliance burden (special category data under GDPR)
  • More complex consent flows
  • AI safety requires more sophisticated guardrails
  • HIPAA compliance needed sooner if therapy market accelerated
  • Greater liability exposure if AI handles crisis situations poorly

Technical Implications​

FeatureRequired ForStage
Sensitive data flag on transcriptsGDPR special category handlingMVP0
Explicit consent checkbox for sensitive dataGDPR lawful basisPilot
Keyword detection for crisis termsSafety escalationPilot
Escalation protocol (notify coach/admin)Duty of carePilot
"Regulated data mode" (enhanced encryption)High-security clientsGA
Separate PHI storageHIPAA therapy readinessGlobal
Clinical data classification tagsTherapy market entryGlobal
EHR integration readinessTherapy market entryGlobal

AI Safety Requirements​

Sasha must handle therapy-adjacent content with care:

IF user mentions self-harm, suicide, or crisis →
  RESPOND with empathy + professional resource referral
  ESCALATE to coach via alert (email/SMS)
  LOG escalation event in audit trail

IF user discusses mental health conditions →
  RESPOND supportively within coaching scope
  DO NOT provide clinical diagnosis or treatment advice
  FLAG content as special category for enhanced protection
  CONTINUE engagement (do not shut down conversation)

IF user asks for therapy/medical advice →
  ACKNOWLEDGE the importance of their concern
  RECOMMEND professional consultation
  OFFER to help prepare talking points for their provider
  DO NOT refuse to engage entirely

Until ReGenesis is licensed for therapy:

  • Marketing: "AI-powered coaching platform for professional and personal development"
  • Terms of Service: "ReGenesis provides coaching support, not therapy. For clinical mental health concerns, please consult a licensed mental health professional."
  • AI disclaimers: "Sasha's insights are coaching suggestions, not clinical assessments"
  • Consent form: Includes explicit consent for processing personal/emotional data
  • Privacy policy: Identifies potential processing of special category data with enhanced protections

References​