TOWARD Ltd provides Executive Coaching, Team Coaching and Leadership and Organisational Development programmes for senior leaders and teams.
We are a Company registered in Northern Ireland (Company Number NI071967). Our registered office is at 33 Massey Avenue Belfast BT4 2JT.
TOWARD Ltd is the Controller of your personal information and is responsible for it. This privacy notice explains how we, TOWARD Ltd may use and process your personal information. In some circumstances, TOWARD Ltd is considered a Processor or Sub-Processor e.g. when your employer provides your information.
We are committed to protecting your privacy and promise to respect your personal information and do all we can to keep it safe. We aim to be clear about how we obtain your details and only process them in ways we believe you would reasonably expect. We always aim to communicate with you respectfully, effectively and efficiently.
TOWARD Ltd is registered with the ICO (ZA028538) and has paid the required fee.
TOWARD Ltd.
A106, 310 Newtownards Road
Belfast
BT4 1HE
data@towardltd.com
Below is a summary of the reasons why we collect personal information, when we collect it, the ways in which we collect it and how we will use it. What we collect and use will depend on how and why you’ve interacted with us.
WHEN WE DELIVER A SERVICE TO YOU
We will process your personal information when we deliver a service to you. This can include your name, contact details, professional history, qualifications and role related information.
WHEN WE DELIVER A SERVICE TO YOU, AS PART OF A CONTRACT
We will process your personal information when we deliver a service to you as part of fulfilling a contractual agreement. For example, as part of a Leadership Development programme commissioned by your employer. This can include your name, contact details, professional history, qualifications and role related information.
In these circumstances, TOWARD Ltd’s legal basis for processing data may be different, typically relying on either Article 6(1)(b) performance of a contract, and Article 6(1)(f) legitimate interest.
WHEN YOU COMPLETE AN ASSESSMENT OR SURVEY
Some of our services require us to process data from assessments (e.g., Hogan, TPS and Baseline surveys), raw evaluation scores and generated personality/risk reports to provide professional development insights. We process this data inline with a contractual agreement and with your consent. You can withdraw your consent at any time, but we may make the commissioning entity aware.
We may also keep notes including summarising 1:1 sessions, action plans, and developmental goals. Where assessments or notes touch upon mental well-being or personality traits that could be considered sensitive, we treat this as Special Category Data.
Comments from this process may be used in a diagnostics insights document and will be high-level aggregate themes that are non-attributional. In some cases, a third party will deliver this service and TOWARD Ltd will not have access to the individual responses.
We will process your personal information to respond to an enquiry about our activities or services. This will usually involve your name, contact details and any other personal information you volunteer in your correspondence.
We will process your personal information in order to communicate for administrative purposes.
When we have a lawful basis to do so, we will process your personal information to send you marketing communications. We will seek your consent for any direct marketing by electronic means (e.g. email, telephone or texts), unless you are a corporate subscriber or we are relying on your soft-opt-in.
Where we contact you in a professional capacity rather than a personal one, we will usually consider you to be a corporate subscriber.
As a corporate subscriber we are permitted to contact you unless you tell us that you would no longer like to hear from us, provided we have a legitimate reason to do so.
Cookies are small text files on your device (computer, smart phone etc). They are made by your web browser when you visit a website. Every time you go back to that website, your browser will send the cookie file back to the website’s server. They improve your experience of using a website, for example, by remembering your preference settings and by measuring your use of a website to ensure that it meets your needs. If you provide your consent for marketing and analytics cookies then we may use information about your use of our website to help us analyse trends and, where it is lawful to do so, display TOWARD Ltd advertising to you on third-party websites.
If you register to attend a TOWARD Ltd event, we will use your personal information to communicate with you details about the event. We may also collect additional information, such as dietary or disability details, to enable your participation and ensure your health and safety while attending.
When you join TOWARD Ltd as a third party subcontractor or supplier, we will process personal information in order to assess your suitability, perform required checks and produce a profile for our clients. Information may include your name, contact details, work history, education, skills, training, dietary, medical or disability information and banking details.
We will process your personal information in order to understand, investigate, and respond to a complaint you raise with us. We will process the minimum amount of personal information that is necessary to respond fully to your complaint. We may ask you for further details where we require them.
We rely on our legitimate interest to conduct background research of publicly available sources into individuals connected to companies or other relevant entities. We may collect personal information from open social networks (e.g. LinkedIn and X), company websites, news archives, the Charity Commission, Companies House and databases sourced from publicly available information.
We may also conduct research into public figures and individuals where we may be about to enter into a commercial relationship or partnership with.
We may obtain your data when it is shared with us by third parties, such as professional assessment providers, partners, or subcontractors acting on our behalf, or through websites such as Eventbrite, LinkedIn or Companies House. These organisations will have their own privacy policies, and/or statements. We always carry out due diligence on organisations who provide personal information to us to ensure it is lawful and secure.
When you interact with us on our social media channels we will use your name or contact handle in order to communicate with you. You may also sign up to a TOWARD Ltd event using a social media website like Facebook. Any data you enter onto a TOWARD Ltd social media page will be sent to us through Facebook or similar social media site. Depending on your settings and the relevant policies and terms of service, when using social media and messaging services like Facebook, you might give us permission to access information about you from those accounts or services.
We may source information from third parties to help us contact individuals in relevant organisations. We will only do this where we have a legitimate interest and feel the organisation would want to hear about our services. We will use this information to guess business email addresses so that we can contact the most relevant member of staff.
With your consent we may use your image in material promoting TOWARD Ltd in print or digital media. Where it is impractical or impossible to seek consent (e.g. large group photographs) we may rely on Legitimate Interests as our legal basis for using these images. We would always seek consent where you, or a handful of individuals are the main focus of an image.
You can withdraw your consent for use in promotional material, and have the right to object. TOWARD Ltd will take all reasonable steps to stop using your image with immediate effect. This may not be possible due to material already in circulation or late states of production.
If you apply to work at TOWARD Ltd we will use the information you provide in your application to assess your suitability for the role you have applied for. Successful applicants may also require a criminal background check. All applicants will be advised of the need for a background check within the job advert and job pack information.
TOWARD Ltd may also process your personal information in order to provide a job reference where we are requested to provide this.
TOWARD Ltd has a responsibility to keep your data up to date and accurate and may include third party sources, partners or open social media accounts to do this (e.g. LinkedIn).
Certain categories of personal information are recognised as particularly sensitive, such as information about your health. This is known as special category data.
We will only process Special Category Data when it is necessary (e.g where we need this information to ensure that we provide appropriate facilities or medical support to enable you to safely participate).
Any special category data (sensitive types of personal data as defined in Article 9 of the UK GDPR) must further be processed only in the line with one of the conditions specified in Article 9(2) e.g. consent or employment.
Automated decision-making is the process of making a decision by automated means without any human involvement. TOWARD Ltd does not undertake complex computerised decision making that produces legal effects, or make decisions solely on automated decision-making.
Profiling analyses aspects of an individual’s personality, behaviour, interests and habits to make predictions or decisions about them. This information is used to classify people into different groups or sectors, or identify associations to build links between different behaviours and attributes.
TOWARD Ltd does not undertake profiling on a large scale without human involvement. Third-party suppliers who provide psychometric assessment on our behalf may use profiling. Personal information is provided to them primarily with your consent, or for the purposes of fulfilling a contract. Please see their individual privacy notices for more information on how your data is handled securely.
There is no legal or statutory requirement for you to provide your personal data to TOWARD Ltd.
Providing certain personal information – such as your name, contact details, and professional history may form part of a contractual requirement. This is necessary for us to fulfill our agreement with you or with the organisation that has commissioned our services (e.g., your employer).
If you choose not to provide the requested information – or withdraw your consent for its use – we may be unable to fulfill our contractual obligations. This means we may not be able to deliver specific services to you.
Under UK data protection law, we must have a lawful basis for collecting and using your personal information. There is a list of six possible lawful bases in the UK GDPR.
The lawful basis we rely on may affect your data protection rights which are set out in the section “Your Rights”. You can find out more about lawful bases, your data protection rights and the exemptions which may apply on the ICO’s website.
If you provide your details to us directly, we will seek consent to process your personal information. Where we do rely on consent, you are entitled to withdraw it at any time.
If we enter into a contract with you (such as when you purchase a product or service from us) or your employer, we will process your personal information to administer and fulfil that contract.
We will process your personal information when it is in your vital interest. For example, to ensure you get urgent medical assistance at one of our programmes.
We may be required to pass on personal information to comply with legal obligations, such as providing tax information to HMRC.
Where it is appropriate we rely on the processing being in our legitimate interests, provided we are confident that such processing is not likely to override your rights and freedoms. For example, sending you direct marketing, provided this is done in an unobtrusive manner.
TOWARD Ltd’s legitimate interests include:
TOWARD Ltd will never share your personal information with another business for their own marketing purposes and we will never sell the information for any reason whatsoever. You are always in control of how we use your personal information in regard to marketing activities.
We will only share your data in order to provide our services to you, in order to enhance our services, or in accordance with a legal obligation.
Sometimes we use external organisations to process personal information on our behalf – for example suppliers, subcontractors and payment or service providers.
Before working with these companies we perform due diligence checks to ensure they provide appropriate safeguards in respect of your personal information and treat it in accordance with the law. We always ensure we have a contract in place with these third party suppliers, and those contracts include robust data protection requirements.
There may be circumstances where we are obliged to share your information without consent. We will only do this when we are required to do so by law, to protect the rights, property or safety of TOWARD Ltd’s employees. We may also need to pass on information if required by law or if a regulatory body, such as HMRC or the police, ask us to.
TOWARD Ltd may occasionally need to use the services of a supplier based outside the UK, leading to your personal information being transferred, processed, and stored outside the UK. Because people risk losing the protection of UK data protection law when their information is sent abroad, we only initiate these “restricted transfers” when specific conditions are met.
When we transfer your data to a separate legal entity outside the UK, we ensure it is protected by one of the following mechanisms:
Adequacy Regulations: We transfer data to countries that the UK government has officially recognised as providing an adequate level of data protection.
Appropriate Safeguards: Where no adequacy regulation exists, we use legally binding agreements such as the UK International Data Transfer Agreement (IDTA) or the International Data Transfer Addendum to the EU Standard Contractual Clauses.
Data Protection Test (TRA): Whenever we rely on these safeguards, we perform a data protection test to ensure the standard of protection in the destination country is not materially lower than in the UK.
You have the right to request a copy of the specific safeguards applied to your data by contacting us at data@towardltd.com.
In general, we will only retain personal information for the necessary period to fulfil the purpose for which it was collected.
This is commonly a three-year retention period for our services. We will only retain information about you past this three-year retention point if it is necessary: such as your name, email address and why and when you used our services.
There may be certain data that we are required by law to keep for longer. For example, we may need to store your information for a certain period of time for accounting and tax purposes.
Our retention and disposal of your personal information is guided by our Data Protection Policy.
In some circumstances, we may anonymise your data or dispose of raw responses or scores. We may retain aggregated analysis, or high level aggregate themes that are non-attributional for future work, research or analysis purposes.
TOWARD Ltd is committed to protecting your data. We take reasonable steps to ensure that any information we hold about you is secure, used for the purpose it was given and protected from unauthorised access.
Please remember, the internet is never 100 per cent secure. When you submit data there is always a risk.
Under UK data protection law, we must have a lawful basis for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website.
Your right of access: You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
Your right to rectification: You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
Your right to erasure: You have the right to ask us to delete your personal information.
Your right to restriction of processing: You have the right to ask us to limit how we can use your personal information
Your right to object to processing: You have the right to object to the processing of your personal information.
Your right to data portability: You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
Your right to withdraw consent: When we use consent as our lawful basis you have the right to withdraw your consent at any time.
Right to object to automated decisions or profiling: Automated decision-making is the process of making a decision by automated means without any human involvement. If your data is being used in this way, you have the right to object.
Where we are processing your personal information with your consent, you can withdraw this at any time.
If you would like to withdraw your consent then please email data@towardltd.com.
If you do ask us to stop sending marketing communications, please note that we will continue to send you administrative communications as needed.
Under the Data (Use and Access) Act 2025, you have a formal right to lodge a complaint directly with TOWARD Ltd if you believe we have infringed data protection legislation.
You can submit a data protection complaint via any channel, though we recommend emailing data@towardltd.com to ensure it is attended to correctly. You do not need to use legal language; simply describe your concern clearly.
You are entitled to make a complaint to the Information Commissioner’s Office at any time. However, we would welcome the opportunity to address your concerns before you feel this step is necessary.
STEP 1: SUBMIT YOUR COMPLAINT
Contact our Data Protection Lead (DPL) directly. While we accept verbal complaints, submitting yours in writing helps us investigate more accurately.
Email: data@towardltd.com
Post: Data Protection Lead, TOWARD Ltd, A106, 310 Newtownards Road, Belfast, BT4 1HE.
STEP 2: ACKNOWLEDGEMENT
We will acknowledge receipt of your complaint as soon as possible, and no later than 30 days after receiving it. At this stage, we may:
STEP 3: INVESTIGATION & RESPONSE
Our DPL will conduct a thorough internal review of our processing activities, security measures, or staff actions related to your concern.
STEP 4: OUTCOME
Our final response will include:
STEP 5: ESCALATION TO THE ICO
Under the Data (Use and Access) Act 2025, you are encouraged to complete our internal complaints process first. If you are still not satisfied with our response, you have the right to lodge a formal complaint with the Information Commissioner’s Office (ICO):
Phone: 0303 123 1113
Website: ico.org.uk/make-a-complaint
let’s talk.
If you are ready for a new approach to your team and its culture then we would like to talk with you today.