Privacy Notice - for psychometrics/ assessments
Updated 27 02 2026
This Privacy Notice explains how Sexton Pendleton Limited (trading as Emily Sexton Coaching”) (“we” “us” “our”) processes personal data in connection with psychometric assessments, including Lumina Spark, Hogan Assessments and other similar tools.
Sexton Pendleton Limited is the Data Controller for the personal data described in this notice. As Data Controller, we will determine the purposes and means of the processing of personal data. We engage trusted third parties as Data Processors to administer and distribute the assessments and reports, in order to provide psychometrics/assessment services to our clients.
For the Primary Colours 360 and Leadership Team Impact Monitor (LTIM), Edgecumbe acts as a Data Processor (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.
1. What Personal Data We Collect
In connection with psychometric assessments, we may collect and process:
Your name and contact details (including email address)
Professional information (such as role, organisation, level of seniority)
Questionnaire responses provided by you
Psychometric reports and assessment outputs
Coaching notes relating to your assessment
Technical data required to administer the assessment platform
Assessment data is provided directly by you via the relevant assessment platform.
In some cases, we may receive your name and contact details from your sponsoring organisation in order to administer the assessment.
2. Purpose of Processing
Your data is processed for the following purposes:
To administer and deliver psychometric assessments
To generate and interpret your individual report
To provide 1:1 debrief sessions and development coaching
To support the design and facilitation of workshops or development programmes
To produce aggregated and thematic group insights for workshop discussion
To maintain appropriate records of professional services delivered
Your individual assessment report will be shared only with you unless you explicitly choose to share it with others.
In workshop settings, anonymised or aggregated data may be used to explore group patterns. In some exercises, participants may be referenced by initials to support discussion.
3. Lawful Basis for Processing
We process psychometric data under the following lawful bases:
Legitimate Interests – to deliver leadership development and coaching services commissioned by a sponsoring organisation.
Contract – where processing is necessary to fulfil a contract for services.
Consent – where required for specific uses (for example, if you choose to share your report beyond the agreed scope).
We do not rely solely on consent where participation forms part of a sponsored development programme.
4. Automated Processing and Profiling
Psychometric tools use automated scoring to generate assessment outputs.
Assessment outputs are used solely for development and coaching purposes.
5. Sharing of Data
We use reputable assessment providers (such as Lumina Learning, Edgecumbe Consulting, and Hogan Assessments) as Data Processors to administer assessments.
Your individual report is not shared with your sponsoring organisation unless agreed, or you choose to do so.
Aggregated or thematic group insights may be used in workshops.
We do not sell personal data.
6. International Transfers
Some assessment providers may store or process data outside the UK.
Where this occurs, appropriate safeguards are in place, such as:
UK adequacy regulations, or
Standard Contractual Clauses or International Data Transfer Agreements.
These safeguards are designed to ensure your data remains protected in line with UK GDPR requirements.
7. Data Retention
We retain:
Individual assessment reports for up to 12 months following programme completion, unless otherwise agreed.
Coaching notes and related records for up to 2 years where required for professional or contractual record-keeping.
Platform-held questionnaire data in accordance with the assessment provider’s retention policies.
Data is securely deleted when no longer required.
8. Your Rights
Under UK GDPR, you have the right to:
Access your personal data
Request correction of inaccurate data
Request erasure (where applicable)
Restrict processing
Object to processing based on legitimate interests
Request data portability (where applicable)
Withdraw consent where consent is the lawful basis
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk.
9. Contact
For any privacy-related queries, please contact: emily@emilysextoncoaching.com
We may update this privacy notice from time to time. Please check this website periodically for updates which will be shared here.