Privacy Policy

01Who we are

Mind-Gap is a purpose-driven leadership development business based in Herefordshire, UK, run by Dave Hider. In this policy, "we", "us" and "our" mean Mind-Gap.

We are the data controller for the personal information described in this policy. We are registered with the Information Commissioner's Office (ICO) under registration reference ZB696522, which you can check on the ICO public register.

Registered with the ICO
Registration reference: ZB696522

Our data protection lead is Dave Hider. You can reach him through our contact page.

This policy covers our website www.mind-gap.co.uk, our online learning platform, and the services we deliver to individuals and organisations.

02What we collect

Information you give us

• Contact details: your name, email address, phone number, job title and organisation when you get in touch, book a chat, sign up for our emails or become a client.
• Learner details: your account details, course progress, assessment results and certificates when you use our online courses.
• Programme information: information shared during coaching, training and facilitation, such as goals, reflections, session notes and action plans.
• Assessment information: psychometric questionnaire responses and profiles (for example Thomas and Belbin assessments) and 360 degree feedback.
• Business details: billing contacts, purchase orders and invoicing information for our client organisations.

Information collected automatically

• Technical data: your IP address, browser type, device type, operating system and approximate location.
• Usage data: the pages you visit, how long you stay and how you found us.

03How we collect it

• Directly from you, through our website forms, email, phone, WhatsApp, online meetings and in person.
• From your employer or the organisation commissioning our work, for example when you are enrolled on a leadership programme.
• From colleagues who provide feedback about you as part of a 360 degree feedback process you are taking part in.
• From our partners, such as Space2Think when you are working towards an ILM qualification delivered in conjunction with them.
• Automatically, through cookies and similar technologies on our website.

04How we use it and why

The law requires us to have a valid reason (a "lawful basis") for using your personal information. Here is what we do and why.

Where we rely on consent, you can withdraw it at any time by contacting us. This will not affect anything we did before you withdrew it.

05Coaching, psychometrics and 360 feedback

This is the heart of our work, so we want to be especially clear.

• Confidentiality: what you share in coaching stays confidential. Where an organisation sponsors your coaching, we agree in advance what (if anything) is reported back, which is usually limited to attendance and broad themes. We will not share the content of your sessions without your agreement, unless we are legally required to or believe someone is at serious risk of harm.
• Psychometric profiles: your results are shared with you and, where agreed as part of the programme, with your sponsoring organisation. Assessments are hosted on the secure platforms of the publishers we are accredited with.
• 360 degree feedback: individual feedback is reported anonymously and grouped so that individual respondents cannot reasonably be identified, except for line manager feedback where this has been made clear in advance.
• Session notes: we may use secure, business grade software, including AI assisted transcription and note taking tools, to help prepare session notes. We only use providers whose terms do not allow your information to be used to train their models, and we will always tell you before a session is recorded.

06Who we share it with

We do not sell, rent or trade your personal information. We only share it where needed, with:

• Your sponsoring organisation, as agreed at the start of any programme.
• Associate coaches and facilitators who deliver work on our behalf and are bound by confidentiality.
• Accreditation and qualification partners, such as Space2Think and the ILM, where you are registered for a qualification.
• Psychometric publishers, such as Thomas International and Belbin, who host assessments.
• Service providers who help us run the business, including Microsoft 365 (email and file storage), Mailchimp (newsletters), Google (website analytics), our website host, our online meeting tools and our accountants.
• Authorities, where the law requires it.

All service providers act on our instructions under written agreements and must keep your information secure.

07International transfers

Some of our service providers store or process data outside the UK, for example in the European Economic Area or the United States. When this happens, we make sure your information is protected by one of the safeguards recognised under UK data protection law, such as:

• a UK government adequacy decision (including the UK Extension to the EU to US Data Privacy Framework for certified US providers); or
• the ICO's International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

Members of our team may occasionally access information from outside the UK. When they do, they use the same secure, access controlled systems and the same standards apply.

08How long we keep it

We keep personal information only for as long as we need it. As a guide:

After this, we securely delete or anonymise the information.

09Keeping it safe

We use appropriate technical and organisational measures to protect your information, including multi factor authentication, encrypted storage and access limited to the people who need it. No system is completely secure, but if a data breach occurs that is likely to put you at risk, we will tell you and the ICO as the law requires.

10Emails and marketing

If you sign up, we will send you practical, research based leadership insights and news about our services. Every email includes an unsubscribe link, and you can also ask us to remove you at any time. We will still send essential service messages about any work we are doing together.

11Cookies

Cookies are small files stored on your device when you visit a website. We use:

• Essential cookies, which make the website and our online courses work properly (for example keeping you signed in). These do not need your consent.
• Analytics cookies, including Google Analytics, which help us understand how visitors use the site so we can improve it. We only set these with your consent.
• Third party content, such as embedded YouTube videos, which may set their own cookies when you play them.

You can change your choices at any time through our cookie banner or your browser settings. Find out more about how Google uses data in the Google Privacy Policy and how to opt out with the Google Analytics opt out add on.

12Your rights

Under UK data protection law, you have the right to:

• Access the personal information we hold about you.
• Correct information that is wrong or incomplete.
• Delete your information in certain circumstances.
• Restrict how we use your information.
• Object to us using your information, including for direct marketing.
• Portability: receive a copy of information you gave us in a commonly used format.
• Withdraw consent where we rely on it.

To use any of these rights, send us a message through our contact page. There is normally no charge, and we will respond within one month. We may need to confirm your identity first.

13Children

Our website and services are designed for adults. We do not knowingly collect personal information from anyone under 18 without the consent of a parent or guardian. If you believe a child has shared information with us, please contact us and we will delete it.

14Complaints

If you are unhappy with how we have handled your information, please tell us first through our contact page. We will acknowledge your complaint promptly and do our best to put things right.

You also have the right to complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113.

15Changes to this policy

We review this policy regularly and will update it when our services or the law change. The date at the top shows when it was last updated. If we make significant changes, we will let clients and subscribers know.