Privacy Policy
This Policy applies as between you, the User of this Website, and Phonics People Partners, the owner and provider of this Website. This Policy applies to our use of any and all Data collected by us in relation to your use of the Website.
Privacy Notice
Last updated: 2 September 2026
| In short: We only use personal information where we have a clear business or legal reason to do so. We do not sell personal information. This notice explains what we collect, why we use it, who may process it on our behalf, and the rights available to you. |
1. Who we are
Phonics People Partners is a trading division of Phonics Digital Limited, a company registered in England and Wales.
Company number: 16327220
Registered office: 2A Torrington Road, Portsmouth, Hampshire, PO2 0TP
Website: www.phonicspeoplepartners.co.uk
Privacy contact: leona@phonicspeoplepartners.co.uk
For the personal information covered by this notice, Phonics Digital Limited trading as Phonics People Partners is generally the data controller, which means we decide why and how that information is used.
2. What this notice covers
This notice applies to personal information we collect through our website and in connection with enquiries, marketing, events, assessments and diagnostics, consultancy services, workshops, client relationships and recruitment activity.
Where we process personal information solely on the documented instructions of a client as part of a consultancy engagement, the client may be the data controller and we may act as a data processor. In those circumstances, the client’s own privacy information may also apply.
3. Personal information we may collect
The information we collect depends on how you interact with us and may include:
- name, job title, role and organisation
- work email address, telephone number and other contact details
- information you provide when making an enquiry, booking a meeting, purchasing a service or corresponding with us
- information provided when you attend an event, workshop or programme
- responses to assessments, questionnaires or diagnostic tools, including the Clarity Snapshot™ and Clarity Scan™
- feedback, survey responses and service preferences
- billing, payment and transaction information
- marketing preferences and records of communications
- professional information contained in CVs or applications where relevant
- technical information relating to use of our website, such as device, browser, IP address, pages viewed and interactions, where collected through our website or permitted analytics tools.
Sensitive information
We do not ask website visitors or Clarity Snapshot™ participants to provide special category personal information about themselves or others. Please do not include unnecessary information about identifiable employees or other individuals, particularly information about health, ethnicity, religion or belief, sexual orientation, trade union membership or other sensitive matters.
Where a client engagement legitimately requires us to handle sensitive employment information, we will do so only where there is an appropriate lawful basis and, where required, an additional condition under data protection law.
4. How we collect personal information
We may collect information directly from you when you:
- complete a form on our website
- contact us by email, telephone, social media or another communication channel
- make an enquiry, request information or book a meeting
- purchase or use one of our services
- complete the Clarity Snapshot™, Clarity Scan™ or another assessment
- attend a workshop, event or programme
- subscribe to updates or marketing communications
- provide feedback or complete a survey
- apply for employment, freelance or associate opportunities.
We may also receive limited business contact information from professional referrals, networking introductions, existing business relationships and publicly available professional sources where it is appropriate and lawful to do so.
5. Why we use personal information and our lawful bases
UK data protection law requires us to have a lawful basis for using personal information. The basis we rely on depends on the purpose and circumstances.
| Purpose | Examples | Typical lawful basis |
| Enquiries and pre-contract discussions | Responding to questions, arranging calls, preparing proposals | Contract / steps at your request; legitimate interests |
| Delivering services | Consultancy, Clarity services, workshops, reports, client administration | Contract; legitimate interests; legal obligation where applicable |
| Business administration | Records, invoicing, finance, insurance, service quality and security | Legitimate interests; legal obligation |
| Marketing and relationship management | Relevant updates, services, events and follow-up communications | Consent where required; otherwise legitimate interests where permitted |
| Website operation and analytics | Security, essential functionality and understanding website use | Legitimate interests for essential operation; consent for non-essential cookies/analytics where required |
| Legal and regulatory matters | Meeting legal obligations, establishing or defending legal rights | Legal obligation; legitimate interests |
6. Clarity Snapshot™, Clarity Scan™ and the Clarity Method™
The Clarity Snapshot™ and Clarity Scan™ are leadership and organisational reflection tools provided by Phonics People Partners as part of the Clarity Method™.
When you complete a digital Clarity assessment, we may collect your name, work email address, organisation, role, organisation size, assessment responses and resulting scores. We use this information to:
- calculate and present your results
- provide relevant interpretation and reflection prompts
- understand your organisational context at that point in time
- respond where you request a Clarity Conversation™ or other support
- deliver any subsequent Clarity service that you choose to purchase.
| Important: The Clarity Snapshot™ is a directional leadership and organisational reflection tool. It is not a psychometric assessment, legal compliance audit, automated employment decision-making tool or definitive measure of organisational performance. Results should not be used in isolation to make employment decisions about individuals. |
7. ScoreApp and other service providers
We use selected third-party technology providers to operate our website and deliver our services. These providers may process personal information on our behalf only where this is necessary for the relevant service.
For the digital Clarity Snapshot™ we currently use ScoreApp, operated by Hyper Targeted Marketing Limited trading as ScoreApp. Under ScoreApp’s subscriber terms, we act as the data controller for participant data and ScoreApp acts as our data processor.
Other providers may include website hosting, email and communications, appointment booking, customer relationship management, cloud storage, accounting and payment, and analytics providers. We expect suppliers processing personal information on our behalf to protect it appropriately and to act in accordance with applicable data protection requirements.
8. Marketing communications
We may contact you about relevant Phonics People Partners services, events, insights or opportunities where you have asked to hear from us or where direct marketing is otherwise permitted by law.
The rules can differ depending on the communication method and whether the recipient is an individual, sole trader, partnership or corporate organisation. Where consent is required, we will seek a clear positive opt-in. Where the law permits us to rely on legitimate interests, we will consider whether the communication is appropriate, proportionate and reasonably expected.
You can unsubscribe or object to direct marketing at any time by using the unsubscribe facility in the communication or contacting us at leona@phonicspeoplepartners.co.uk. We may retain a minimal suppression record so that we can respect your preference in future.
9. Who we may share personal information with
We do not sell or rent personal information to third parties.
Where necessary, information may be shared with:
- our trusted technology and professional service providers
- professional advisers such as accountants, lawyers or insurers
- payment, booking or communications providers used to deliver a service
- competent authorities, regulators, courts or law-enforcement bodies where required by law
- a prospective purchaser, buyer or successor if all or part of the business is sold, transferred or reorganised, subject to appropriate safeguards.
We do not share personal information with third parties for their own unrelated marketing purposes without an appropriate lawful basis.
10. International transfers
Some service providers or their sub-processors may process personal information outside the United Kingdom. Where this happens, we will use an appropriate transfer mechanism or safeguard required by UK data protection law, such as UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another lawful safeguard.
11. How long we keep personal information
We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including to meet legal, accounting, contractual, insurance and reporting requirements.
| Type of information | Typical retention approach |
| General enquiries | Normally up to 12 months after the enquiry becomes inactive. |
| Prospective client information | Normally up to 24 months where there remains a reasonable business relationship or legitimate interest. |
| Client and contractual records | For the client relationship and normally up to six years afterwards where required for contractual, legal, taxation or insurance purposes. |
| Clarity Snapshot™ responses | Normally up to 24 months after completion, unless the participant becomes a client or a longer period is reasonably required for an associated service. |
| Marketing records | Until you unsubscribe or we no longer have a lawful reason to retain the information. A minimal suppression record may be kept to honour opt-outs. |
| Recruitment information | Normally up to six months after the relevant process unless a longer period has been agreed or is otherwise justified. |
We may retain anonymised information for longer where it can no longer reasonably identify an individual and is useful for service improvement, research or statistical analysis.
12. Keeping information secure
We use appropriate technical and organisational measures designed to protect personal information from accidental or unlawful loss, misuse, alteration, unauthorised disclosure or access. Access is limited to people and service providers who have a legitimate need to use the information.
No internet-based system can be guaranteed to be completely secure. If we become aware of a personal data breach, we will assess and respond to it in accordance with our legal obligations.
13. Cookies and similar technologies
Our website may use cookies and similar storage or access technologies.
- Strictly necessary technologies may be used where they are essential to provide, secure or operate the website and do not require consent under applicable rules.
- Non-essential technologies, including analytics or marketing technologies, will only be used where we have an appropriate legal basis and, where consent is required, after you have made a clear choice through our cookie controls.
- You can use our cookie controls to accept, reject or manage non-essential technologies and can change your choice later.
Where Google Analytics 4 or another analytics service is enabled, it is used to help us understand website performance and visitor interaction. Any non-essential analytics technology will be subject to the consent controls applicable on the website.
More detailed information about cookies and similar technologies used on the website may be provided through our cookie banner or a separate Cookie Notice where appropriate.
14. Links to other websites
Our website may contain links to websites or services operated by third parties. We are not responsible for how those organisations collect or use personal information. Please review their privacy information before providing personal data to them.
15. Your data protection rights
Depending on the circumstances, UK data protection law may give you the right to:
- access the personal information we hold about you
- ask us to correct inaccurate or incomplete information
- ask us to erase personal information in certain circumstances
- ask us to restrict certain processing
- object to certain processing, including direct marketing
- receive certain information in a portable format where the right applies
- withdraw consent at any time where we rely on consent
- raise concerns about qualifying automated decision-making where applicable.
These rights are not absolute and may depend on the circumstances and lawful basis for processing. To exercise a right, contact leona@phonicspeoplepartners.co.uk. We may need to verify your identity before responding.
16. Questions and complaints
If you have a question or concern about how we use personal information, please contact us first so that we have an opportunity to address it.
You also have the right to complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection. You can find current contact details and guidance at www.ico.org.uk or telephone 0303 123 1113.
17. Changes to this Privacy Notice
We may update this notice from time to time to reflect changes in our services, technology, business practices or legal requirements. The latest version will be published on our website and will show the date of the most recent update.