1  Privacy Statement

1.1 We take your privacy seriously and this privacy statement (Assessment Privacy Statement) sets out how we will handle your personal data securely and in accordance with your rights.

1.2 GatenbySanderson Limited (we, us, our) is a registered data controller under the terms of the UK General Data Protection Regulation (GDPR). Details of our notification to the data protection regulator may be found in the Information Commissioner’s Office Public Register of Data Controllers at ico.org.uk under registration number Z9032296. Our registered office address is at 14 King Street, Leeds, West Yorkshire, LS1 2HL.

1.3 Our Data Protection Officer is: Nathan Tittensor.


2  General Information

2.1 You have been asked to participate in this diagnostic assessment (Assessment) as part of the services we provide to your current or potential future employer/employment organisation (Employer) in order to complete some or all of the following, to:

  1. help us assess, analyse and interpret your interests, values, motivations and behavioural styles, reasoning and other cognitive abilities in your current employment role or in relation to a future role; and/or
  2. help you understand your skills and level of experience and to identify your strengths, areas for future development and further training requirements; and/or
  3. aggregate, compare, interpret and analyse your assessment results with those of other individuals (including other applicants, your colleagues and other employers) and our own market data to help your Employer identify and assess the leadership capabilities in its existing workforce and its future leadership requirements; and/or
  4. assist your Employer with identifying and developing customised support and training programmes (and delivering or assisting with the delivery of such programmes).

The Assessment Services

2.2 This Assessment Privacy Statement explains what personal data we collect about you and the purposes for which we may use such personal data in connection with the Assessment Services and how we handle your personal data to ensure that we protect your rights.

2.3 Please read this Assessment Privacy Statement carefully to understand how we will treat your personal data. In this Assessment Privacy Statement, references to you or your shall mean you as a participant in the Assessment and/or our Assessment Services.

2.4 By signing this Assessment Privacy Statement and (in respect of our Assessment Data, as defined below) by participating in our Assessments you will be regarded as having accepted the terms of this Assessment Privacy Statement and to our processing of your personal data in accordance with its terms. Please do not sign this Assessment Privacy Statement or participate in our Assessments if you do not agree to the terms of this Assessment Privacy Statement.


3  What information do we collect?

3.1 Employment-focused diagnostic assessments are a way of assessing your approach, interests, values, motivations and behavioural styles and cognitive abilities against your current or a potential future employment role or job level (Assessment Criteria). Other Assessments you could be asked to participate in could focus more on your organisation, team or the performance of your colleagues (such as organisation engagement or culture surveys, team performance questionnaires or colleague performance assessments). Our Assessments may take a variety of forms, including personality questionnaires, reasoning tests, surveys and behavioural simulation exercises

3.2 Assessments are typically carried out online using either:

  1. our own Assessment software (our Software); and/or
  2. software developed or provided by our trusted third party assessment service providers (Third Party Assessment Providers),
although in some cases you may be asked to complete the Assessment on paper.


3.3 During the course of the Assessment you will be asked to:

  1. provide us with certain information such as, your name, date of birth, address, email address, contact number, age, gender, job title/position of employment within your Employer's organisation and the length of time you have been in your current position of employment (Background Data). This Background Data is collected to identify you, to help us understand your role of employment and to assist us with any future communications with you and/or your Employer; and
  2. answer a series of questions and/or to provide information, responses or situation-based solutions to enable us to assess your approach, behavioural styles, interests, values, motivations and cognitive abilities in light of the Assessment Criteria (Assessment Data).

Sensitive personal information

3.4 During the course of the Assessment we may also ask you to provide personal data which the Data Protection Act 2018 (DPA 2018) and the UK GDPR regards as sensitive or special categories of personal data, such as information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health or conditions, sexual orientation and/or information relating to any criminal convictions you have or offences you may have committed (Sensitive Data).

3.5 We may ask you to provide such Sensitive Data by completing our equal opportunities form (Equal Opportunities Form) online during the course of the Assessment.

3.6 Please note that:

  1. you are not required to provide us with any Sensitive Data (as you can always provide a "prefer not to say" response when completing the questions on our Equal Opportunities Form); and
  2. by answering the questions contained in our Equal Opportunities Form (i.e. by providing a response other than a "prefer not to say" response) you will signify your explicit consent to such information being processed by us for the purposes stated in this Privacy Statement.

Information relevant for reviewers

3.7 If you are have been asked to provide feedback on a participant as part of their 360, this section provides details on how your personal information is used and for what purpose.

  1. What information we collect – we may collect your name, contact details and role title and, where relevant, your business relationship to the participant and your ratings and comments for the individual you have provided feedback on. We may also collect sensitive information relating to your racial or ethnic origin, religious or philosophical beliefs, physical or mental health or conditions and sexual orientation, anonymised and aggregated for research purposes only (See 3.6 above).
  2. What we use your information for:
    1. to contact you and enable you to access our assessment platform and complete your review.
    2. to aggregate or report data in relation to your role or relationship with the participant.
Your personal information will not be used for any other purpose listed within this privacy notice.


4  What do we use your information for?

4.1 You have the right to be told of the legal basis and purposes for the processing of your personal data. We are relying on your explicit consent to the processing of your personal data (including any Sensitive Data as referred to above). This means that if you exercise your right to withdraw your consent (please see paragraph 8 below) we will no longer be able to process your personal data. Please note that we may retain a copy of your personal data in accordance with our data retention policy.

4.2 We may use your information to:

  1. process your completed Assessment and to review and analyse your Assessment Data in accordance with the Assessment Criteria;
  2. liaise with our Third Party Assessment Providers (or where you complete your Assessment at a third party test centre (i.e. a venue other than our premises or your Employer's premises), with the relevant test centre provider) to obtain the results of your completed Assessment;
  3. liaise with our Third Party Assessment Providers to enable them to process your Assessment and provide us with your Assessment Data;
  4. discuss and provide you with feedback in relation to your Assessment Data, including identifying your strengths, areas for improvement and future training needs (which may include face-to-face meetings with our consultants and associates);
  5. review and analyse your Assessment Data with your Employer to help them understand your skills and abilities and the skills of your Employer's current leadership force;
  6. aggregate your Assessment Data with that of other candidates nominated to take part in our Assessments by your Employer (Aggregate Data) to analyse, interpret and benchmark this data against:
    1. different departments, divisions, grades or other sub-groups within your Employer's organisation;
    2. aggregate data we, or our Third Party Assessment Providers have collected from other candidates / organisations to whom we provide our Assessment Services; and/or
    3. our leadership competency models,
    to help your Employer assess the strengths in its current leadership force; and
  7. to assist your Employer with identifying and developing customised support and training programmes (and delivering or assisting with the delivery of such programmes),
on the basis that such processing is necessary in order to provide the Assessment Services in accordance with the agreement in place between us and your Employer and on the basis that you have expressly consented to such processing, either by:
  1. ticking the box at the bottom of this Assessment Privacy Statement (where you are completing an Assessment online); or
  2. by signing this Assessment Privacy Statement below (where you are completing this Assessment on paper).

4.3 Please note that if you do not wish for us to use your personal data for the purposes set out in paragraph 4.2, above, we will be unable to provide our Assessment Services and you should not proceed with this Assessment.

4.4 We may also use your personal data for our own market intelligence gathering purposes, to enable us to understand the recruitment market and prepare demographic, analytical, statistical or market information (which may include aggregating your data with, and benchmarking it against, data received from other clients, employers, individuals completing our Assessments and our Third Party Assessment Providers) and to improve our services (all on the basis that your personal data will be completely anonymised and you will not be capable of being identified from such information if we share it externally).


5  Who do we share your information with?

5.1 In connection with our Assessment Services, we may share your personal data with the following parties:

  1. our data hosting/support service providers who process and store data on our behalf;
  2. our professional advisors, employees, consultants, associates, data analysts and psychologists;
  3. your Employer and any directors, officers and employees of your Employer who are entitled to receive such personal data in connection with our Assessment Services;
  4. our Third Party Assessment Providers;
  5. test centre providers where your Assessment is carried out at a test centre/venue hosted by a third party (ordinarily, we anticipate that your Assessment will be carried out at our premises or your Employer's premises, however this may not be possible in all circumstances);
  6. our third party training/coaching providers who may provide further development and training services to you and/or your Employer;
  7. our trusted third party emailing service provider whom we use to upload and send email communications to you; and
  8. any of our group companies, which means our group and any other companies which may be added to our group from time to time.

5.2 We may also share your personal information with third parties:

  1. in the event that we, our business, or substantially all of its assets are acquired by a third party (in which case personal data held in our databases will be one of the transferred assets);
  2. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with you, or to protect our rights, property, or safety of our employees, customers, or others (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction); or
  3. if such disclosure is necessary in connection with any investigation or complaint regarding your use of our Software or any third party software in connection with any Third Party Assessment.


6  Transfers outside of the United Kingdom and the EEA

6.1 In accordance with paragraph 6.2, where you are completing:

  1. an Assessment which is carried out using our Software, then we will not transfer your personal data outside of the United Kingdom and the European Economic Area (EEA); or
  2. an Assessment using software provided by one of our Third Party Assessment Providers, we cannot guarantee that your personal data will not be transferred outside of the United Kingdom and the EEA for the purposes of processing your Assessment results and/or for the storage of such data.

6.2 We shall ensure that any such transfers are lawful and with an adequate level of protection;, that your personal is kept secure in accordance with the DPA 2018 and the GDPR and that our Third Party Assessment Providers are obliged to ensure that equivalent protections apply to your data.


7  How long do we store your personal data for?

7.1 We only store your personal information for as long as necessary for the purposes listed in paragraph 4. This data is retained for a period of four years, calculated either from the date you last accessed your data from our portal directly, or when we originally uploaded the data, whichever is the latest.


8  What are your rights?

8.1 You may exercise your rights below by contacting us using the contact details in paragraph 12 of this Assessment Privacy Statement.

8.2 Access to your personal data: You may request access to a copy of your personal data by contacting us using the contact details in paragraph 12.

8.3 Right to withdraw: You may withdraw your consent to us processing your personal data at any time. Please contact us using the details located in paragraph 12 if you would like to withdraw your consent and we will delete your data in line with your right to erasure at 8.5 below. Please note that in the event that you wish to exercise your rights under this paragraph 8.3, we may be unable to provide, or to continue to provide, our Assessment Services.

8.4 Rectification: You may ask us to rectify inaccurate information held about you. If you would like to update the data we hold about you, please contact us using the details in paragraph 12 and provide the updated information. Please note that we shall periodically check that any Background Data provided by you is accurate.

8.5 Erasure: You may ask us to delete your personal data. If you would like us to delete the personal data we hold about you, please contact us using the details in paragraph 12, specifying why you would like us to delete your personal data. Please note that in the event that you wish to exercise your rights under this paragraph 8.5, we may be unable to provide, or to continue to provide, our Assessment Services.

8.6 Portability: You may ask us to provide you with the personal data that we hold about you in a structured, commonly used, machine readable form, or ask for us to send such personal data to another data controller by contacting us using the details in paragraph 12.

8.7 Right to object: You may object to our processing of your personal data pursuant to this Assessment Privacy Statement. Please contact us using the details in paragraph 12, providing details of your objection. Please note that in the event that you wish to exercise your rights under this paragraph 8.7, we may be unable to provide, or to continue to provide, our Assessment Services.

8.8 Make a complaint: You may make a complaint about our data processing activities to a supervisory authority, for the UK this is the Information Commissioner's Office, at ico.org.uk.


9  Cookies Policy

9.1 Where you are accessing the Assessment via our website at (www.gatenbysanderson.com) (Website), please note that certain parts of the Website and the Assessments use "cookies" (Cookies) to keep track of your visit and to help you navigate between sections.

   What are Cookies?

9.2 A Cookie is a small data file that certain websites store on your computer's hard-drive when you visit such websites. Cookies can contain information such as your user ID and the pages you have visited.

   What do we use Cookies for?

9.3 We use Cookies on the Website (including in the Assessment) to enable us to deliver content that is specific to your interests, give us an idea of which parts of the Website you are visiting, to recognise you when you return to the Website and in order for our Assessments to process your Assessment Data. Our Cookies do not directly read any other data from your computer's hard-drive or read Cookies created by other websites that you have visited.

   How do I reject or accept Cookies?

9.4 You may refuse to accept Cookies by activating the setting on your browser which allows you to refuse the setting of Cookies. If, however, you select this setting you may be unable to access and complete the Assessment, as the information you provide will be lost each time you navigate between Website pages.

9.5 See http://www.allaboutcookies.org for more information about Cookies and how to disable them in your browser.

   Third-party content

9.6 Please note that our Third Party Assessment Providers may also use Cookies in connection with the provision of their Assessments over which we have no control.


10  Security and Data Storage

10.1 We will treat all of your information in strict confidence and we will endeavour to take all reasonable steps to keep your personal data secure once it has been transferred to our systems. We adopt and ensure that our third party service providers are obliged to adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal data, and data stored on our databases.

10.2 Please note that the internet is not a secure medium and we cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information and dealing online over the internet and will not hold us liable for any breaches of your data protection rights attributable to the transmission of your personal data over the internet.


11  Changes to this Assessment Privacy Statement

11.1 We may modify this Assessment Privacy Statement from time to time, so please review it regularly.

11.2 If we change this Assessment Privacy Statement we shall notify you via email, using the email address originally provided to us by your Employer.

11.3 This Assessment Privacy Statement was last amended on 18th January 2024.


12  Contact

12.1 If you have any queries relating to this Assessment Privacy Statement or our use of your personal data or you wish to exercise any of your rights under this Assessment Privacy Statement please contact:

  1. our privacy team at privacy@gatenbysanderson.com (or such other email address as may be displayed on the "Contact Us" section of any of the Websites from time to time); or
  2. (b) our Data Protection Officer by post at GatenbySanderson Limited, 14 King Street, Leeds. West Yorkshire, LS1 2HL.