Legal - Privacy Notice

The Lucent Collective Limited, registered in England and Wales under company number 16455050, provides leadership development, coaching, facilitation and related consultancy services to organisations and individuals.

For some personal information, Lucent acts as a data controller, which means we decide why and how that information is used.

When an organisation engages us to deliver a programme or other service and provides us with information about its employees or participants, we may instead act as a data processor on that organisation's behalf. In those circumstances, the organisation remains responsible for determining how and why that personal information is processed, and our processing is governed by our agreement with that organisation.

For privacy enquiries, please contact hello@thelucentcollective.com.

The information we collect depends on your relationship with Lucent.

It may include:

• your name, business email address, job title and organisation;
• contact information you provide when you contact or work with us;
• information about your participation in a leadership programme, workshop, coaching engagement or other Lucent service;
• attendance or scheduling information where this is required for an engagement;
• correspondence and communications with us;
• limited coaching information where it is reasonably necessary to support a coaching engagement;
• audio or video recordings in the limited circumstances where a session needs to be recorded and participants have been appropriately informed; and
• information you choose to provide when giving us feedback.

We do not routinely request special category personal data, such as information about health, ethnicity, religion or sexual orientation. Please do not provide this type of information unless it is relevant and there is an appropriate reason and arrangement for us to process it.

We aim to collect only the personal information that is reasonably necessary for the relevant purpose.

We may receive personal information:

• directly from you;
• from your employer or another organisation that has engaged Lucent to provide services;
• through communications with us, including email, meetings and our website;
• through your participation in Lucent programmes, coaching or other services; or
• through specialist platforms used as part of a particular engagement.

Where an organisation provides us with participant information so that we can deliver services on its behalf, that organisation is responsible for ensuring that it has an appropriate basis for providing the information to us.

Depending on the circumstances, we may use personal information to:

• respond to enquiries and communicate with you;
• manage our relationship with clients and prospective clients;
• arrange, administer and deliver leadership programmes, workshops, coaching, facilitation and other services;
• communicate with programme participants where authorised to do so;
• manage scheduling and, where required, attendance;
• provide appropriate follow-up after an engagement;
• maintain appropriate records of the services we have delivered;
• manage contracts, invoicing and our business administration;
• improve and evaluate our services using feedback and other appropriate information;
• meet our legal, regulatory and professional obligations; and
• establish, exercise or defend legal rights where necessary.

Where we retain a limited historical record of a completed programme for our own business record-keeping purposes, we aim to keep this to the minimum information reasonably required. This may include a participant's name, organisation, programme or cohort and relevant dates.

We may use this information to maintain an accurate record of services delivered, support continuity in client relationships and respond to subsequent queries.

Where Lucent acts as a data controller, the lawful basis we rely on will depend on the circumstances.

This may include:

• Contract - where processing is necessary to enter into or perform a contract with you.
• Legitimate interests - where processing is reasonably necessary for our business or professional activities, or those of a client or other party, and those interests are not overridden by your rights and interests.
• Legal obligation - where we need to process information to comply with the law.
• Consent - where we have specifically asked for and obtained your consent.

We do not rely on consent where another lawful basis is more appropriate.

Where Lucent acts as a processor on behalf of a client organisation, the client is responsible for determining the applicable lawful basis for that processing.

Lucent does not routinely maintain detailed coaching notes.

Where limited notes are reasonably necessary to support a coaching engagement, we keep them securely and review and delete them when they are no longer required.

We also do not routinely record coaching, facilitation or programme sessions.

Where a recording is required for a particular purpose, participants will be informed. Recordings are retained only for as long as reasonably necessary for the purpose for which they were made and are normally deleted within six months, and sooner where that purpose has been fulfilled.

Personal information held directly by Lucent is ordinarily stored within our Microsoft 365 environment, including services such as OneDrive, Outlook and Teams.

We use appropriate security measures to protect personal information. These include multi-factor authentication for Microsoft 365, password and/or biometric protection of devices, encrypted hard drives and active endpoint security protection.

We restrict access to personal information to those who need it for the relevant purpose and take reasonable steps to avoid unnecessary collection, copying and sharing of personal information.

We use trusted technology and service providers to support the operation and delivery of our services.

These include Microsoft 365 for email, document storage, collaboration and related business activities, and Zoom where it is used for online meetings.

These providers may process personal information on our behalf and are subject to appropriate contractual and data-protection arrangements where required.

Some engagements may also involve specialist third-party platforms, such as behavioural, profiling or development platforms. These platforms may operate under their own contractual and privacy arrangements with users, client organisations or another relevant party.

Where Lucent has authorised facilitator access to personal information held within such a platform, we access and use that information only as reasonably necessary to deliver the relevant engagement. Unless otherwise agreed, we do not download or create a separate Lucent-held copy of the underlying platform data.

Lucent may use generative artificial intelligence tools to support aspects of our own business and work.

As part of our standard practice, we do not submit identifiable client participant personal information, identifiable coaching material or client recordings to general-purpose generative AI services.

If an engagement requires a materially different use of personal information involving an AI service, we will ensure that there is an appropriate data-protection basis and, where required, appropriate client instruction or approval before doing so.

We do not sell personal information.

We may share personal information where reasonably necessary with:

• technology and service providers supporting our business and delivery of services;
• professional advisers where necessary;
• a client organisation where information relates to services we are providing for that organisation;
• regulators, authorities or other parties where required by law; or
• other parties where you have asked or authorised us to do so.

We aim to share only the information necessary for the relevant purpose.

Some of the technology providers we use operate internationally.

Where personal information is transferred outside the United Kingdom and UK data-protection law requires additional safeguards, we take steps to ensure that an appropriate lawful transfer mechanism or other required protection is in place.

We do not keep personal information for longer than reasonably necessary for the purpose for which it is held, taking account of our contractual, legal and legitimate business requirements.

Retention periods therefore vary according to the type of information and the reason we hold it.

For programme administration, participant contact details are reviewed and deleted when they are no longer reasonably required for administration, follow-up or an ongoing or subsequent engagement.

Following an engagement, we may retain a limited historical record of programme participation for our own business record-keeping purposes. This may include a participant's name, organisation, programme or cohort and relevant dates. We minimise the information retained for this purpose and do not retain participant contact details unless there is a separate reason for doing so.

Recordings are deleted when the purpose for which they were created has been fulfilled and normally no later than six months after recording unless a different arrangement has been agreed.

Limited coaching notes are reviewed and deleted when they are no longer reasonably required.

Information required for contracts, accounting, taxation, legal or compliance purposes may be retained for longer where appropriate.

Information that has been genuinely anonymised so that an individual can no longer be identified may be retained and used without being treated as personal data.

Depending on the circumstances, UK data-protection law may give you rights in relation to your personal information, including the right to:

• ask for access to personal information we hold about you;
• ask us to correct inaccurate or incomplete information;
• ask us to delete personal information in certain circumstances;
• ask us to restrict how we use your information in certain circumstances;
• object to certain processing, including processing based on legitimate interests;
• receive certain information in a portable format where the right to data portability applies; and
• withdraw consent at any time where we are relying on consent.

These rights are not absolute and whether a particular right applies will depend on the circumstances.

Where Lucent processes your personal information solely on behalf of a client organisation, we may need to refer your request to that organisation as the relevant data controller.

If you have questions about this Privacy Notice, want to exercise your data-protection rights or have concerns about how we use your personal information, please contact:

Email: hello@thelucentcollective.com

You also have the right to complain to the Information Commissioner's Office (ICO), the UK regulator for data protection.

We would welcome the opportunity to address any concerns directly first, but you are not required to contact us before approaching the ICO.

We may update this Privacy Notice from time to time to reflect changes in our services, systems or legal requirements.

The latest version will be published on our website with the date it was last updated.