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.