PRIVACY NOTICE
Sexton Pendleton Limited (trading as Emily Sexton Coaching)
Last updated: 15 September 2026
1. About us
This Privacy Notice explains how Sexton Pendleton Limited (“we”, “our”, “us”) collects, uses, stores and protects personal information in connection with our coaching and leadership development services.
Sexton Pendleton Limited is the organisation responsible for your personal information. We are registered in England and Wales under company number 16091315.
Registered office: 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ
ICO registration reference: ZB855440
Email: emily@emilysextoncoaching.com
We provide coaching and leadership development services to adults. This Notice applies to information we process in connection with those services.
2. What personal information we collect and why
Depending on the engagement, we may collect and use:
· your name and contact details;
· your company, job title, role and areas of responsibility;
· information about your professional context, goals and development needs;
· information provided by your employer or sponsoring organisation about the coaching engagement;
· information you share with us during coaching, together with appropriate coaching records and agreed actions;
· communications between you and us;
· payment and transaction information, where relevant;
· information about complaints, claims or other issues relating to our services;
· audio or video recordings, only where recording has been specifically agreed;
· website or service usage information where relevant; and
· psychometric assessment and 360-degree feedback information where these are used as part of your engagement.
We use this information to set up and provide coaching, prepare for and follow up sessions, administer assessments, maintain appropriate professional records, manage the business relationship, meet legal or regulatory obligations and protect our legitimate business interests.
3. How we lawfully use your information
For ordinary personal information, we generally rely on one or more of these legal grounds:
· Legitimate interests — for example, providing and managing coaching, maintaining appropriate professional records and administering an engagement.
· Contract — where processing is necessary to enter into or perform a contract with you.
· Consent — where we have specifically asked for your consent for a particular use of your information.
· Legal obligation — where we need to use information to comply with the law.
Where an employer or sponsoring organisation commissions and pays for coaching, we may process the coachee’s information as necessary to deliver and manage the agreed service.
4. Psychometrics and 360-degree feedback
Where an assessment is used, we will explain its purpose, how the information will be used and who will receive the resulting report before you complete it.
We may also use psychometric information from participants to develop and present aggregated and/or anonymised group-level themes, patterns and insights as part of a workshop or facilitated session that forms part of the agreed services. These insights will not be presented in a way that is intended to identify an individual participant or disclose their individual psychometric results.
Hogan
For Hogan assessments, the assessment is completed directly by the coachee using a link or access code provided for the engagement. The resulting Flash Report is provided to us as the coach.
The Hogan assessment is used to support coaching and leadership development. It can help the coachee understand how they typically show up at work, including their usual ways of relating to others and approaching their work, behaviours that may become less helpful under pressure, and the values and motivations that influence what they find rewarding at work.
We use the Hogan results to support reflection, discussion and development within the coaching relationship. We do not use the Hogan assessment to make decisions about employment, promotion, selection or performance management.
We provide the Hogan Flash Report to the coachee. We do not share it with the employer, line manager or HR unless the coachee separately agrees.
3 Minute Mile may be involved in arranging the Hogan assessment. Where it is involved, it may process contact or administrative information for the purpose of initiating the service. 3 Minute Mile states in its privacy policy that it can act as both a controller and processor, depending on the activity. Hogan has its own privacy notice and terms for information it processes in its systems.
Lumina Spark
For Lumina Spark, we set up and administer the project through the Lumina Learning portal. We provide Lumina Learning with the information needed to create the project and generate the assessment link.
The participant then enters their own details and completes the questionnaire directly through the Lumina Learning portal.
The participant can access their Lumina Spark Portrait through the portal. Alternatively, we may download the Portrait and send it to the participant.
The Portrait is used to support reflection, discussion and development within the coaching relationship. Unless otherwise agreed for the engagement, we do not share the Portrait with the employer, line manager or HR.
For participant data used for the Lumina project, we are the data controller and Lumina Learning acts as our data processor. Lumina Learning may also process certain platform or account information for its own purposes under its own privacy notice.
360-degree feedback
Where a 360-degree feedback exercise is used, we provide Edgecumbe Consulting Group Limited (“Edgecumbe”) with the information needed to set up the exercise. Edgecumbe then invites nominated respondents, such as colleagues, peers or line managers, to provide feedback through its online portal.
Respondents enter their own details and submit their feedback directly to Edgecumbe. The feedback may include ratings and written comments about workplace behaviours, leadership and performance.
Edgecumbe processes the information on our instructions and produces the 360 report. We use the report to support coaching and leadership development.
Who receives the report will be agreed as part of the particular engagement. Where the agreed arrangement is for the report to be provided directly to us as the coach, we receive and hold the report for the coaching engagement.
We ask respondents to focus on workplace behaviours, leadership and performance and not to include unnecessary health, disability or other sensitive information in free-text comments.
5. Special category data
Special category data is personal information that receives additional protection because it is particularly sensitive. It includes information revealing:
· racial or ethnic origin;
· political opinions;
· religious or philosophical beliefs;
· trade union membership;
· genetic information;
· biometric information used to identify someone;
· physical or mental health, including a medical condition, diagnosis or disability;
· sex life; or
· sexual orientation.
We do not routinely ask for or collect special category data as part of our coaching or assessment services.
You may nevertheless choose to share special category data during a coaching conversation. It may also occasionally appear unexpectedly in an assessment process, for example when a respondent includes information about another person’s health or disability in a free-text comment that we have not asked them to provide.
Where special category data is provided unexpectedly, we will take appropriate steps to minimise, redact or delete it where appropriate. Where we need to retain or use special category data relating to a client, we will ensure that we have an appropriate legal basis and the additional legal protection required for this type of data.
Where we rely on explicit consent, we will ask for that consent separately and clearly, explain what information we are asking to process and why, and keep a record of the consent. You can withdraw consent at any time.
6. Confidentiality
The content of your coaching conversations is confidential. We will not ordinarily share the content of coaching conversations with your employer, sponsoring organisation, line manager or HR without your agreement.
There are limited circumstances in which we may need to disclose information, including where disclosure is required by law or a valid court order or subpoena, where disclosure is required or appropriate under applicable law in relation to illegal activity, where we reasonably believe disclosure is necessary to prevent an imminent or likely risk of serious harm to you or another person, or where disclosure is necessary to meet a legal or professional obligation.
Where possible and appropriate, we will discuss the need for disclosure with you before taking action.
As part of normal professional practice, we may discuss general themes or issues arising from coaching in professional supervision. We will do this in a way that protects confidentiality and does not identify you or your organisation.
Where we are engaged in organisational coaching, the information shared with an employer or sponsor will be limited to what has been agreed for the engagement. Confidential coaching content will not be shared unless you have agreed or disclosure is otherwise permitted or required by law.
7. Professional supervision and ICF credentialing
As part of our professional development, coaching supervision and ICF credentialing, we may need to keep limited information about coaching engagements, such as the fact that coaching has taken place and certain engagement details.
Where information could identify you, we will only provide it where it is necessary for the relevant purpose and where an appropriate legal basis or consent is in place. We will not share the confidential content of your coaching sessions for these purposes.
8. Automated decision-making
We do not use automated decision-making or profiling that produces legal or similarly significant effects on you. Assessment results are interpreted and used by us as your coach and are not used by us to make employment or other significant decisions about you.
9. Who we share information with
We only share personal information where there is a lawful basis to do so and where the sharing is necessary for the relevant purpose.
Assessment providers
Hogan Assessments — for Hogan assessment administration and reports. Hogan generally acts as a processor or sub-processor when processing assessment information on behalf of a client, although it may act as a controller for some of its own business activities.
Lumina Learning — acts as our processor for participant data used for the Lumina Spark project, and may act as a controller for some of its own platform or account activities.
Edgecumbe Consulting Group Limited — acts as our processor for the 360-degree feedback service and processes the information on our instructions.
3 Minute Mile — may be involved in arranging or administering Hogan assessments. Its own privacy policy states that it can act as both a controller and processor, depending on the activity.
Other partners & service providers
· Microsoft and other IT/service providers we use to operate our business;
· secure electronic-signature, communication or document-management services where relevant; and
· professional or legal advisers where necessary
Through our association with Bulmer Group International, we may share data/personal information with employees of Bulmer Group International in order to provide the agreed coaching services that have been arranged with you/your organisation.
10. International transfers
Some service providers may process personal information outside the UK. Where this occurs, we use appropriate safeguards required by UK data protection law.
Hogan Assessment Systems, Inc. is based in the United States and states that information processed through its assessment platforms is gathered and stored in the US. Hogan states that it participates in the UK Extension to the EU-US Data Privacy Framework for UK personal data.
Lumina Learning states that it stores participant data in the UK or EEA wherever possible. Where approved service providers process data outside the UK, Lumina states that appropriate safeguards are used.
Edgecumbe states that personal information is primarily processed in the UK and EEA but that some approved service providers are outside the UK, with appropriate transfer safeguards.
Bulmer Group International is headquartered in Australia and has employees around the world. Where we are sharing personal information/data internationally, we take the appropriate measures to ensure your personal data is stored and processed safely. For information on how Bulmer Group International stores and handles data, please refer to their Privacy Notice. https://www.bulmergroup.com/privacy-policy
11. How we keep your information secure
We take reasonable technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.
Information held by us is stored using password-protected devices and systems, with access limited to what is reasonably necessary for the relevant purpose.
12. How long we keep your information
We keep personal information only for as long as it is needed for the purposes for which it was collected, including where necessary to meet legal, accounting or reporting requirements.
· Contact, identity, financial and transaction records: generally 6 years where required for tax or other legal purposes.
· Coaching records: up to 2 years after the end of the coaching engagement, then securely deleted, unless a longer period is required for a legal obligation or to establish, exercise or defend a legal claim.
· Hogan Flash Reports: 1 year after the end of the coaching engagement, then securely deleted, unless a longer period is required for a legal obligation or to establish, exercise or defend a legal claim.
· 360-degree feedback reports: up to 2 years after the end of the coaching engagement, then securely deleted, unless a longer period is required for a legal obligation or to establish, exercise or defend a legal claim.
· Lumina Spark Portraits held by us: up to 2 years after the end of the coaching engagement, then securely deleted, unless a longer period is required for a legal obligation or to establish, exercise or defend a legal claim.
The assessment providers may keep information within their own systems for different periods under their own privacy notices and contractual arrangements. Our retention periods apply to information held by us.
13. Your data protection rights
You have rights over the personal information we hold about you. Depending on how we are using your information, these include:
· Access — ask us for a copy of the personal information we hold about you.
· Correction — ask us to correct information that is inaccurate or incomplete.
· Erasure — in certain circumstances, ask us to delete information we hold about you.
· Restriction — in certain circumstances, ask us to stop using your information while an issue is considered.
· Objection — in certain circumstances, object to our use of your information, particularly where we rely on legitimate interests.
· Data portability — in certain circumstances, ask for information you have provided to us to be transferred to you or another organisation in a usable electronic format.
· Withdrawal of consent — where we rely on your consent, including explicit consent for special category data, withdraw that consent at any time.
· Rights relating to automated decision-making — we do not make decisions about you solely by automated means that have legal or similarly significant effects.
These rights are subject to legal conditions and exceptions. To exercise your rights, contact emily@emilysextoncoaching.com. We may need to verify your identity before responding.
14. Where we get personal information from
· directly from you;
· your employer or sponsoring organisation, where relevant to the engagement;
· assessment providers and their systems, where relevant;
· respondents who provide 360 feedback through the assessment provider’s platform; and
· publicly available sources, where appropriate.
15. Complaints
If you have concerns about how we use your personal information, please contact us first at emily@emilysextoncoaching.com so that we can try to resolve the issue.
You also have the right to complain to the Information Commissioner’s Office (ICO). Further information is available at https://ico.org.uk/make-a-complaint/.
16. Changes to this Privacy Notice
We review this Privacy Notice from time to time. The version in force is the version published on our website. Where a material change affects how we use your personal information, we will take appropriate steps to notify you.