Privacy Notice
How we collect, use and protect personal information.
This notice in brief
- We are Axis Culture Group, a UK leadership education and coaching consultancy.
- We collect contact, professional and, where relevant, coaching, programme and evaluation information from clients, programme participants, partner organisations and website visitors.
- We use it to deliver our coaching and programmes, to evaluate what they achieve, and, only where you have agreed, to keep you updated about our work.
- We share limited information with trusted partners and the service providers who help us run our programmes and business. We never sell personal data.
- You can ask to see, correct or delete your information at any time, and you can complain to the Information Commissioner's Office if you are unhappy with how we have handled it.
- We are registered with the ICO as a data controller, reference ZB946061.
1. Who we are
Axis Culture Group Ltd ("Axis", "we", "us", "our") is a UK-based leadership education and professional development consultancy. We work across executive coaching, early careers education, leadership programmes, coach certification, and organisational culture and development services, for individuals and for organisations including schools, colleges, universities, councils, NHS organisations and employment services.
Axis Culture Group is a small organisation and has assessed that it is not required to appoint a statutory Data Protection Officer. Ethan von Fintel acts as the privacy contact for the organisation and can be reached using the details above.
2. Who this notice covers
This notice applies if you are:
- an individual client receiving executive coaching or another individual service from us
- a participant on one of our programmes, such as Future-Ready Foundations or In the Middle of Everything, whether you access this directly or through your employer, school, college or a partner organisation
- a contact at an organisation we work with or are in discussion with, including institutional and B2B contacts
- a contact at a partner organisation that works with us or helps us deliver our services
- a visitor to our website, a listener to our podcast, or a subscriber to our newsletter or social media channels
- an applicant for our coach certification programme, or for a role at Axis
Where a programme is delivered through a school, college, employer or other partner, that organisation may also independently process your data under its own privacy notice. This notice covers what Axis Culture Group itself does with your information.
3. The information we collect
| Category | Examples |
|---|---|
| Identity and contact details | Name, job title, organisation, email address, phone number |
| Professional and employment details | Role, band or grade, sector, years of experience, and, for organisational programmes, your line manager's name and contact details |
| Programme and coaching content | Session notes, coaching goals, workbook and application form answers, and evaluation survey responses, including confidence and wellbeing scores |
| Special category data, only with your explicit consent | Equality monitoring information such as age band, gender, ethnicity and disability status; access needs or health information you share so we can support you safely in a session |
| Financial information | Billing details and payment records for coaching sessions and courses. Card payments are handled by our payment provider; we do not store full card numbers |
| Marketing and communications data | Email address, marketing preferences, and how you engage with our emails, newsletter and social media |
| Enquiry and qualification data | When an organisation submits our website enquiry form: organisation size, indicative budget, timescale and the areas you are interested in, alongside your contact details |
| Technical and website data | IP address, browser and device information, and cookies or similar technologies on our website |
| Recruitment information | CVs, applications and references, for coach certification or roles at Axis |
Where it comes from
- directly from you, through sign-up and application forms, email, phone or in-person conversations
- from your employer or line manager, where a programme is arranged through your organisation
- from partner organisations, where they promote or refer you to one of our programmes
- from publicly available professional sources, company websites or business intelligence tools, when we research prospective institutional partners
- from cookies and analytics on our website
4. How we use your information, and our lawful basis
Under UK data protection law, we must have a lawful basis for everything we do with personal data. The table below sets out our main purposes and the basis we rely on for each.
| Purpose | Lawful basis under UK GDPR |
|---|---|
| Delivering the coaching, programme or service you have asked for | Performance of a contract, or steps taken at your request before entering one |
| Evaluating the impact of our programmes and reporting findings to funders and partners | Legitimate interests, in evidencing and improving our programmes. We rely on your explicit consent for any special category data included in this |
| Managing client relationships, invoicing and accounts | Performance of a contract; legal obligation, for accounting and tax purposes |
| Sending you marketing about our services | Consent, or, for existing clients, our legitimate interest in telling you about similar services (sometimes called a soft opt-in). You can opt out at any time |
| Business development, including researching prospective institutional partners | Legitimate interests, in growing our organisation responsibly |
| Equality, diversity and inclusion monitoring | Explicit consent |
| Recruitment | Steps taken at your request before entering a contract, and our legitimate interest in recruiting fairly |
| Complying with our legal and regulatory obligations | Legal obligation |
Where we rely on legitimate interests, we have considered whether our interests are overridden by your rights and freedoms, and we do not use legitimate interests as a basis for special category data or for marketing to people who have not engaged with us before.
5. Special category data
A small amount of what we collect is "special category data" under UK GDPR, meaning it reveals something particularly sensitive, such as health or ethnicity. We only collect this where it is optional and you have explicitly agreed, or where you have chosen to share it with us directly, for example:
- equality monitoring questions on a programme evaluation form, used only to understand whether our programmes are reaching a representative range of people
- access needs or health information you choose to share so we can support you properly during a session
- information about a child's special educational needs, disability or health, shared with us by a parent or carer taking part in our SEND Management for Parents programme
Any special category data we hold is reported only in anonymised, aggregated form. It is never linked to your individual coaching or evaluation responses in anything we share with a partner, employer or funder.
6. Children and young people
Some of our programmes, such as Future-Ready Foundations, are designed for young people, including sixth form and college learners who may be under 18. Where we work with young people, we:
- collect only the information needed to deliver the programme safely and to evaluate it
- write our forms and consent language in clear, age-appropriate terms
- work with the school, college or organisation delivering the programme to ensure appropriate parental or guardian consent and safeguarding arrangements are in place, in line with their own policies
- where a participant is under 13, obtain parental or guardian consent before collecting personal data directly from them online, in line with the ICO's Children's Code
Where a parent shares information about their child
Our SEND Management for Parents programme works with parents and carers, but naturally involves them sharing information about their child, who is not themselves an Axis client or website user. In this situation:
- we collect only what the parent chooses to share, and only what is relevant to supporting them
- the child's information is used solely to help us support the parent well, and is never used to market to or profile the child
- we apply the same security and confidentiality standards to this information as to any other special category data
If you are a parent, guardian or educator with a question about how a young person's data is handled on one of our programmes, please contact us using the details in section 14.
7. Who we share your information with
We do not sell personal data. We share it only where necessary, with the following types of organisation:
- Delivery partners who help us deliver programmes jointly, under a formal partnership agreement
- Programme partners, who receive only anonymised, group-level evaluation findings, unless you have separately and explicitly agreed to be contacted by them directly, or the programme is delivered in partnership with them
- Service providers who process data on our behalf under contract, including our payment provider, our CRM, lead sourcing tools, workflow automation, email platforms, survey tools, our website platform and design tools
- Professional advisers, such as our accountant or solicitor, where necessary
- Regulators, funders or authorities, where we are required to by law or by the terms of a funding agreement
Every service provider we use is required by contract to protect your data to a standard consistent with UK data protection law, and to use it only for the purposes we specify.
8. International transfers
Some of the service providers listed in section 7 store or process data outside the UK, including in the United States. Where this happens, we ensure appropriate safeguards are in place, such as the UK's International Data Transfer Addendum, the UK's own adequacy regulations, or the provider's participation in a recognised data protection framework.
9. How long we keep your information
| Type of data | How long we keep it |
|---|---|
| Client and coaching records | For the duration of our relationship with you, plus 6 years afterwards for accounting and legal purposes |
| Programme evaluation data | For the reporting period of the relevant programme, plus 3 years |
| Marketing data | Until you unsubscribe, or after 24 months of no engagement |
| Recruitment records | 6 months after the recruitment process closes, if your application is unsuccessful |
| Website and analytics data | As set out in our cookie notice, typically no longer than 26 months |
10. Keeping your information secure
We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or disclosure. This includes restricting access to those who need it, using encrypted connections where data is transmitted, and requiring our service providers to maintain equivalent protections under contract. No system is completely secure, and we review our practices as our tools and ways of working evolve.
11. Your rights
Under UK data protection law, you have the right to:
- be informed about how we use your personal data, which is the purpose of this notice
- request access to the personal data we hold about you
- request that we correct any inaccurate or incomplete data
- request that we delete your data, in certain circumstances
- request that we restrict how we use your data, in certain circumstances
- request that we provide your data to you, or to another organisation, in a portable format
- object to us using your data, including for direct marketing
- withdraw your consent at any time, where we rely on consent, without affecting anything we did before you withdrew it
We do not use your personal data for any decision-making that is based solely on automated processing and that has a legal or similarly significant effect on you.
To exercise any of these rights, contact us using the details in section 14. We will normally respond within one month.
12. Your marketing preferences
Where you have agreed to receive marketing from us, you can change your mind at any time by using the unsubscribe link in any email, or by contacting us directly. Opting out of marketing does not affect our use of your data for other purposes, such as delivering a programme you are enrolled on.
13. Cookies and website analytics
Our website uses cookies and similar technologies to help it function and to understand how it is used. You can choose whether to allow analytics cookies when you first visit the site, and you can manage or delete cookies at any time through your browser settings. Disabling some cookies may affect how parts of the site, including our booking and payment experience, work.
14. How to contact us, and how to complain
If you have any questions about this notice, or about how we use your personal data, please contact:
If you are unhappy with how we have handled your personal data, you also have the right to complain to the Information Commissioner's Office, the UK's independent regulator for data protection.
15. Changes to this notice
We may update this notice from time to time, for example as our programmes, tools or legal obligations change. We will post the current version on our website with its date, and will let you know directly if a change materially affects how we use your data.
16. Our ICO registration
This registration can be checked at any time on the ICO's public register of fee payers, at ico.org.uk.
Axis Culture Group Ltd | Privacy Notice | V2.1 | ICO reference ZB946061 | Last updated April 2026