Privacy Notice for psychometrics and 360 feedback reporting
Updated 09 Sept 2025
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 participate in psychometrics and 360 feedback reporting processes. We are committed to safeguarding your privacy and ensuring compliance with applicable data protection laws.
Data Controller Information
The data controller for your personal data is Sexton Pendleton Limited (trading as Emily Sexton Coaching and represented by Emily Sexton). Sexton Pendleton Limited is registered at 71-75 Shelton Street, London, WC2H 9JQ. Please send an email to emily@emilysextoncoaching.com for any inquiries regarding your personal data.
Data Processors
To provide 360 feedback reports, we engage a third-party distribution partner: Edgecumbe.
Edgecumbe acts as a Data Processor under our instruction under a 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. The results of the assessment(s) are primarily used for selection and/or development by the requesting organisation.
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 requested by you or your organisation
Purpose of Processing
We process your personal data for the following purposes:
To provide tailored coaching, developmental insights and/or feedback as part of the agreed services
To identify areas for personal and professional growth.
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 requested us via an email, Sales Order or Coaching Agreement to provide an assessment (e.g. 360 report or hogan assessment) for yourself or someone within your organisation.
Consent : When processing personal or special category data, we often rely on consent to help us meet our data protection obligations. We may seek your consent verbally or in writing and will document this accordingly.
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) unless otherwise agreed in writing between the Coach (Data Controller), Coachee and Sponsor.
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 month 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 (coachee) or sponsor (customer) 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.
Data Security Measures
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or destruction.
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 in this Privacy Notice.