Throughout this privacy policy, there are words and phrases that have a specific meaning or that we are using in a special way. They are:
When youuse our services, you are entrusting us with your information. OTD Ltd understands that this is a big responsibility, and we work hard to protect the information shared with us. This notice explains how OTD Ltd collects, uses, stores, andprotects personal data when delivering its services.
OurTraining Department contact details are as follows:
Address: Floor Suite 37, OTDLtd Second, 39 Ludgate Hill, Birmingham B3 1EH
Contact number: (0)121 6474355
Thefollowing companies and websites are within scope of this privacy policy:
https://otdcarpediem.azurewebsites.net/
https://evaluations.otd.uk.com/
https://www.strengthsprofile.com/
https://eu.themyersbriggs.com/
https://paradigmpersonality.com/
http://colin@gautreyinfluence.com
As part of ourlearning and development services, Our Training Department Ltd may use digitallearning, coaching and feedback platforms provided by carefully selected thirdparties. This includes the use of Yoodli, an AI enabled communication coachingplatform, to support learner development. Where such platforms are used,personal data will be processed in accordance with this privacy notice andapplicable data protection laws.
We have appointed a data protection officer (DPO) who isresponsible for monitoring and providing guidance with our GDPR status.If you have any questions about this privacy notice, including any requeststo exercise your legal rights, please contact the DPO using the contactinformation below.
Our Data Protection Officer: LianBemrose (lian@OTD.uk.com)
All Customers, Learners and AssociateBusiness Coaches, should ensure that any information that they provide to OTDLtd is accurate and up to date. Any changes to information, should besent to GDPR@otd.uk.com. For example, a change of address, bank details, or ofany errors to personal data.
We only collect and use your personal information when the law allows us to. Most commonly, we use it where:
· The data subject (you) has given consent to the processing activity taking place
· If the processing is necessary for the performance of a contract
· If the processing is necessary for compliance with a legal obligation to which the controller is subject
· If the processing is necessary for the purpose of the legitimate interest pursued by our partners or us
Where legitimate interest is identified as a lawfulbasis, we will undertake a legitimate interest assessment, which is a three-parttest covering:
The purpose test – to identify the legitimate interest
Necessity test – to consider if the processing is necessary for the purpose identified
Balancing test – considering the individual’s interests, rights or freedoms and whether these override the legitimate interests identified.Legitimate interests identified areas follows, photographs taken for case studies (where permission is given), monitoring and assessing progress of development programmes, data processed via feedback forms, some marketing content and data processed for certification purposes. Legitimate interests also include the use of digital and AI-enabled learning tools to monitor, assess, and support communication skills and professional development as part of our training programmes.
Special category data
“Special categories” of particularly sensitive personal data require higher levels of protection. We need to have further justification for collecting, storing, and using this type of personal data.
OTD Ltd will only collect such information necessary for the performance of your contract with us and legitimate interest.
Where appropriate, we may seek your written authorisation to process special categories of data. Upon such an occasion, we will endeavour to provide full and clear reasons at that time in order for you to make an informed decision. In any situation where consent is sought, please be advised that you are under no contractual obligation to comply with a request. Should you decline to consent, you will not suffer a detriment.
Where audio or video recordings are processed through digital coaching platforms, this data is not used for biometric identification purposes. Any voice or video data isprocessed solely to support communication development and learning outcomes.OTD Ltd does not use such data for identity verification or profiling.
Most of the information we process comes from you. We process it so we can reply to you, and when you contact us again, we know what you asked before, what you were sent, and what you told us.
Typically, we are collecting name, contact details, how we came across you, and background information from you or published by you on social media or freely accessible on the internet, on why you might be interested in our services or a relevant contact for our business.
If we email you or respond to an email sent to us at any of our business email addresses, a copy of that email will also be stored.
If you make an enquiry via our website, we will keep details of that enquiry and response for our data retention period.
We do not routinely keep special category data. To the extent we hold this, it was supplied or made publicly available by you.
Customers
Once you buy something from us, we will collect information from you at the point of sale. This will include the information we collect from Prospects (above). We collect your email address, phone number and postal address so we can provide what we have contracted to, invoice you and keep proper records of our business relationship.
We process your data to support the delivery of the services you have bought. We keep records of the services provided to you, and information you give us, so we can support you when needed and advise you of any additional services you may need.
When we are processing data about you on behalf of a customer, we are operating under the banner of our customer’s data privacy policy. We will refer any enquiry from you to them, as they are the “data controller” responsible for dealing with your query. But we will support that by providing relevant information to our customer for passing to you.
Associate Business Coaches & Suppliers
We collect information on potential and actual Associate Business Coaches and suppliers. This is mostly provided by you, but we do add to it the same kind of data we use for Prospects (see above).
If you become an Associate Business Coach or supplier, we keep a copy of the contract between us and your bank details so we can pay you. We also keep a record of invoices/payments for accounting purposes.
We keep a record of the work you undertook for us/our customers along with any comments, reviews or suggestions about that work including complaints (if any) and their resolution.
This information is all needed to manage our customer relationships and our supply chain.
Learners
We collect information about potential and actual Learners, in the first instance this information may be passed to us by your employer. Depending on the type of learning programme you embark on with OTD Ltd, you may add to this over time. This could be in the form of learning portals or other necessary documentation to sustain the learning.
The data we hold on you is added to during the course of your learning journey, such data will be added by your Associate Business Coach and / or employer.
Unless otherwise agreed at the beginning of your learning journey, your information will not be shared with another third party, or your employer unless the reasons for doing so are to enable us to continue your development, and to fulfil our contract with your employer.
We will keep a record of the learning you undertook with us, with any comments, reviews or suggestions to support your learning journey. This information will be held securely on a learner management system.
Financial and credit card details
We do not receive or store your credit card details. Credit card payments are handled by an external secure processor in accordance with their data security policies. We receive limited information from our processor for us to tie up your payment with your invoice.
When you pay us by BACS or direct transfer, we know only what the bank tells us, which is usually the name of the person (Company) who paid us and how much and the reference number.
We do not keep credit scores nor use credit reference agencies.
We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations and professional obligations that we are subject to. All personal information collect has a defined retention period, which is in-line with our retention policy.
We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place robust access controls which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.
We have policies and procedures to handle any potential data security breaches and data subjects, third parties and any applicable regulators will be notified where we are legally required to do so.
We have ensured that all employees have had information security and data protection training. If you would like more details of the security we have in place, please see "additional information", section 15 of this policy.
OTD Ltd may process limited personal information relating to children under the age of 16 where this is necessary to support approved work experience placements or similar educational activities.
In such cases, the personal information we collect is limited to what is necessary and may include the child’s first name, surname, school issued email address, and curriculum vitae or application details. This information is provided directly by the school, the child, or their parent or legal guardian.
All work experience placements involving children under the age of 16 are arranged and approved by the relevant school, and parental or legal guardian consent is obtained prior to any processing of personal data. Where required, we rely on the consent of the parent or legal guardian and, where appropriate, our legitimate interests in supporting educational development.
We use this information solely for the purpose of administering the work experience placement, maintaining appropriate contact, and meeting safeguarding, legal, and insurance obligations. We do not use children’s personal data for marketing purposes.Children’s personal data is handled with additional care and security and is retained only for as long as necessary to fulfil the purpose for which it was collected, or as required by law. Once it is no longer needed, the information is securely deleted.
If a parent, legal guardian, or school has any questions about how a child’s personal data is processed or wishes to exercise data protection rights on behalf of a child, they may contact us using the details set out in section 15 of this privacy notice.
In this section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
• Right to Object
• Right of Access
• Right to be informed
• Right to Rectification
• Right to Erasure
• Right to Restrict Processing
• Right to Data Portability
• You can exercise this right if:
• Processing relies on legitimate interest
• Processing is for scientific or historical research
• Processing includes automated decision-making and profiling
• Processing is for direct marketing purposes
• You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge.
• We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you.
• We are required to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right.
• If you believe the personal data we hold about you is incorrect or incomplete, you have the right to correct this and, you may exercise this rightalong with the right to restrict processing until these corrections are made.
• If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.
• You may ask us to restrict the processing of your personal data. This means we will still hold it, but not process it. This is a condition, alright, which may only be exercised when:
• Processing is unlawful
• We no longer need the personal data, but it is required for alegal process
• You have exercised your right to object to processing and requireprocessing to be halted while a decision on the request to object is made.
• If you are exercising your right to rectification
• You can request that your personal data be transferred to another controller or processor in a machine-readable format if:
• Processing is based on consent
• Processing is by automated means (i.e. not paper-based)
• Processing is necessary for the fulfilment of a contractual obligation
If you have any questions about these rights, please see "additional information", section 15 of this policy.
Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.
Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.
Our website uses cookies. Please see our cookies policy for full details of the cookies used.
Your personal data is not used to make decisions that have legal or similarly significant effects based solely on automated processing. Where digital coaching platforms are used, automated insights or feedback may be generated to support learning and development. These insights are advisory only and are generated within parameters defined by the customer or learning programme.
They are intended to support human led coaching, reflection, and decision making and do not replace human judgement.
Our Training Department Ltd may disclose your personal data, listed in section 3 to some third parties to help us deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. We may use several or all of the following categories of recipients:
• Business partners, suppliers, contractors for the performance of any contract we enter into with them or you
• Companies within our group where necessary for administrative purposes and to provide services to you
• Third parties that support us to provide products and services (e.g. IT support, cloud-based software services, providers of telecommunications equipment)
• Marketing services providers
• Payment service providers
• Recruitment service providers
• Professional advisors e.g. HR, lawyers, auditors
• Web analytics and search engine provider to ensure the continued improvement and optimisation of our website.
• Providers of digital learning, coaching, and AI enabled communication feedback platforms used to support the delivery of our training programmes.
• Providers of cloud based productivity and collaboration services, including Microsoft 365, used for secure email communication, document storage, and service delivery.
• Providers of customer relationship management and workshop management systems used to administer and deliver services.
In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the European Economic Area (EEA).
We may share personal information to third parties outside of the European Economic Area (EEA). Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.
Where personal data is processed by third-party learning platforms outside the UK or EEA, including AI-enabled coaching platforms, OTD Ltd ensures appropriate safeguards are in place, such as Standard Contractual Clauses or other approved transfer mechanisms, in accordance with data protection laws.
Where personal data is transferred outside of the EEA/UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:
• EU Standard Contractual Clauses + UK Addendum
• International Data Transfer Agreement
• Binding Corporate Rules
• An exception as defined in Article 49 of the EU GDPR
For more information about transfers and safeguarding measures, please contact us using the information in section 15.
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact us via email on GDPR@otd.uk.com.
Alternatively, you can contact us:
By Post: Floor Suite 37, OTD Ltd Second, 39 Ludgate Hill, Birmingham B3 1EH
By Phone: (0)121 647 4355
Alternatively, you can make a complaint to the Information Commissioner’s Office:
By Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
By Website: Click Here
By Phone: 0303 123 1113
Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this privacy policy or if you wish to receive more in-depth information about any topic within it, please contact us on GDPR@otd.uk.com.
If you have any questions about how third party learning platforms, including AI enabled coaching tools, process your personal data, please contact our Data Protection Officer using the details above.
We keep this Policy under regular review. This Policy was last updated on 09/02/26.
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
