Privacy Notice for psychometrics and 360 feedback reporting
Updated 23 02 2026
Introduction
This privacy notice explains how Sexton Pendleton Limited (trading as Emily Sexton Coaching) (“we” “our”) collects, uses, and protects your personal data when you engage us in delivering psychometric tools/assessments such as a 360-degree feedback reports/questionnaires or personality insight reports such as Hogan or Lumina Spark. We are committed to safeguarding your privacy and ensuring compliance with applicable data protection laws.
Data Controller Information
Where we have been engaged to deliver a psychometric assessment/personality insight report, we, Sexton Pendleton Limited, act as the Data Controller, which means we determine the purposes and means of the processing of personal data. In order to fulfil our contractual services, we engage third party distributors to provide the psychometric/assessment tools and insight reports.
For the Primary Colours 360 and Leadership Team Impact Monitor (LTIM), Edgecumbe acts as a Data Processor under our instruction (see Data Processing Agreement) and is committed to complying with applicable data protection laws. They implement appropriate technical and organisational measures to safeguard your personal data and will not use your personal data for any other purpose. For more information, see Edgecumbe’s Privacy Statement.
For Hogan assessments, the data you provide, including the replies you submit during the assessment(s), will be processed by Hogan. For information on how they handle data, you can read their Privacy notice on their website. https://www.hoganassessments.com/privacy-policy/
Where we are using Lumina Spark portraits, the questionnaires and portraits (reports) are provided by Lumina Learning. You can find out more about how they handle data in their General Privacy Notice.
Types of Personal Data Collected
We may collect the following types of personal data:
Your full name, company name and job title
The names and job titles of any participants providing feedback
Psychometric data, 360 performance ratings and other relevant information supplied by you, or your organisation, including feedback provided by peers, managers, and direct reports.
Any additional information relevant/required to deliver the assessment
Purpose of Processing
We process your personal data for the following purposes:
To provide tailored coaching, developmental insights and/or feedback (e.g. to identify areas for personal and professional growth) as part of the agreed services
Lawful Basis for Processing
Our lawful basis for processing your personal data is:
Contractual Necessity: Processing is necessary for the performance of a contract with you in which you have engaged us in writing (email or formal Agreement) to deliver an assessment (e.g. 360 feedback report or personality insights report) for yourself or someone within your organisation.
Consent: To help us meet our obligations for processing special category data, we may seek your consent (verbally or in writing), where applicable, and will document this accordingly.
Confidentiality - sharing your data/report
Once we receive the assessment report from the data processor (above), we will share the report exclusively with the data subject (the coachee/participant), unless it has been otherwise agreed in writing between Sexton Pendleton (Data Controller), the Coachee/Participant, and Sponsor (the paying customer if different from the coachee/participant).
Data Retention Period
You may withdraw your consent to the processing of the data you provided at any time and such data will be deleted from our systems. At this point, we will also notify all relevant data processors on your behalf to request that all data is safely deleted from their systems. Please contact emily@emilysextoncoaching.com for guidance.
At Sexton Pendleton Limited it is our standard procedure to retain assessment reports (Primary Colours 360 Reports and Hogan Flash Reports) for up to one year following completion of the assessment. After that time, your report will be deleted from our systems.
The company may retain raw personal data until such time as the data subject or sponsor requests that the data be destroyed, or we deem there to be no further value in retaining the data.
Data Subject Rights
You have the following rights under GDPR:
The right to access your personal data.
The right to rectify any inaccurate personal data.
The right to request the erasure of your personal data.
The right to restrict processing of your personal data.
The right to object to the processing of your personal data.
To exercise your rights, please send an email to emily@emilysextoncoaching.com
Data Security Measures
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or destruction.
We do not sell your data to third parties for marketing purposes.
International Data Transfers
If we transfer your personal data outside the UK or EU, we will ensure that appropriate safeguards are in place to protect your data in accordance with applicable data protection laws.
Hogan is based in the US and all Hogan assessments data is stored there. Hogan has undertaken thorough GDPR readiness and impact assessments to ensure the proper policies and procedures are in place for compliance. To find out more, you can read the Hogan Statement on GDPR Compliance here: https://www.hoganassessments.com/privacy-policy/gdpr-compliance/
Contact Information
For any questions or concerns regarding your personal data, please contact emily@emilysextoncoaching.com
Updates to the Privacy Notice
We may update this privacy notice from time to time. Please check this website periodically for updates which will be shared here.