Sarah Cochrane joined the Employment Team at Carson McDowell in 2012. Sarah attained a degree in law (LLB Honours) from Queens University in 2005 before embarking on the Legal Practice Course (LPC) at the College of Law in Chester later that year. Sarah trained with DAC Beachcroft LLP in Manchester and qualified as a solicitor into the Employment & Pensions Team in 2009.
Sarah is dual qualified in England & Wales and Northern Irish law. She provides practical employment advice to employers from a wide variety of industries throughout the UK. This advice and assistance is given mainly to Human Resource officials and management and ranges from day to day ad hoc issues to more detailed, complex advice and project work. Sarah acts for clients in defending claims in the Industrial Tribunal and Fair Employment Tribunal. Sarah also assists Carson McDowell’s Corporate Team by providing employment advice in relation to mergers and acquisitions.
Sarah is a committee member of the Employment Law Group for Northern Ireland and a member of the Employment Lawyers Association.
Artificial intelligence is transforming learning and development across workplaces. One of the most promising innovations is the digital coach - an AI-powered tool that provides employees with personalised guidance, career support, and wellbeing prompts. For HR teams, digital coaching offers the potential to deliver learning that is smarter, faster, and more consistent. Yet its use also raises important legal, ethical, and relational questions.
Opportunities for HR and Learning
Personalised learning
Digital coaches can adapt to each individual’s pace, strengths, and goals, creating targeted learning paths that traditional programmes cannot match. This flexibility can be particularly valuable for organisations with dispersed teams across Northern Ireland.
Consistent, data-driven insight
AI tools can provide 24/7 support and generate aggregated data that helps HR identify skills gaps, track development trends, and plan future investment. When handled responsibly, this information strengthens strategic decision-making rather than monitoring individual performance.
Where HR Needs to Take Care
- Data protection and privacy
Digital coaches process large volumes of personal information. Employers must comply with UK GDPR and the Data Protection Act 2018, complete a Data Protection Impact Assessment, and ensure that data transfers and vendor contracts safeguard confidentiality and security.
- Fairness and equality
AI systems can reflect bias in their training data, potentially disadvantaging protected groups. Northern Ireland’s equality laws, including the Disability Discrimination Act 1995, deem less favourable treatment on protected grounds unlawful and therefore learning technologies must be fair and inclusive. Regular reviews and human oversight are essential.
- Employee rights and fair process
If digital coaching influences decisions about promotion, performance, or redundancy, it shouldn’t be forgotten that employees retain the right to a fair process and transparency about how conclusions are reached. Digital coaching should not be the ultimate decision maker and again, human input is key.
EU AI Act implications
Even though the EU AI Act does not automatically apply in the UK, it is still relevant for many organisations based in the UK including those that supply AI to the EU, use it for business within the EU, or whose AI outputs affect EU-based employees. Contractual obligations in EU supply chains may also apply.
The Act categorises AI by risk: unacceptable (banned), high (includes AI in employment or learning), limited, and minimal or no risk.
High-risk AI systems must include human oversight, clear transparency for employees, bias mitigation, and robust data protection. Key deadlines include AI literacy from February 2025, banned systems from February 2025, provider obligations from August 2025, and high-risk product safety from August 2027.
Even if outside the EU, Northern Ireland organisations using AI tools that affect EU employees should adopt these standards to ensure fairness, transparency, and risk management.
The Human Connection Still Matters
AI can personalise learning, but it cannot replace the trust, empathy, and context that come from human relationships. Line managers play a crucial role in interpreting feedback, supporting wellbeing, and linking development goals to organisational needs.
Overreliance on digital coaching risks reducing meaningful dialogue between employees and their managers. The best approach is a blended one — combining AI-driven insight with genuine human interaction. This ensures that coaching remains grounded in understanding, accountability, and connection.
Practical Takeaways for HR Teams
• Complete a DPIA before introducing digital coaching platforms.
• Be transparent about how the system works and what data it uses.
• Blend AI insights with regular, human-led development conversations.
• Review outputs for fairness and equality compliance.
• Ensure provider contracts include strong data protection and confidentiality terms.
Final Thought
Digital coaching can enrich learning and development, offering flexibility, insight, and personalisation. Yet its true success depends on responsible use — one that protects privacy, promotes fairness, and preserves the human relationships that underpin trust and growth in every workplace.
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