Privacy Policy
A legal disclaimer
Last updated: 28 September 2026
This Privacy Policy explains how The S.W.I.T.C.H. Lab ("we", "us", "our") collects, uses and protects personal data when you visit theswitchlab.co.uk (the "Website"), contact us, or use our leadership development, coaching and training services.
We are committed to handling personal data lawfully, fairly and transparently in line with the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 ("PECR"), and the Data (Use and Access) Act 2025 where applicable.
1. Who we are
The data controller is:
The SWITCH Lab Limited, trading as The S.W.I.T.C.H. Lab Company number: 15802773 (registered in England and Wales) Registered office: C/O Vantage Accounting, 1 Cedar Office Park, Cobham Road, Wimborne, Dorset, BH21 7SB, UK Trading address: 61 New Street, Salisbury, Wiltshire, SP1 2PH, UK VAT number: GB 470 820 989 Email: jonathanbowder@theswitchlab.co.uk Telephone: +44 7594 900570
If you have any questions about this policy or how we use your data, contact us using the details above. We are a small business and have not appointed a Data Protection Officer; privacy queries are handled by Jonathan Bowder, Director.
2. Personal data we collect, why, and our lawful basis
2.1 Website enquiries
What: your first name, last name, email address, the content of your message, and any other details you choose to give us (for example your organisation or phone number). Why: to respond to your enquiry and, where appropriate, discuss and propose our services. Lawful basis: our legitimate interests in responding to business enquiries; or, where you are asking us to take steps towards a contract, that contract.
2.2 Clients, workshop participants and coaching clients
What: name, job title, employer, work contact details, information about your role and development goals, attendance and programme records, notes from coaching or workshop sessions, and feedback you give us. If your organisation is our client, we may receive your details from your employer. Why: to deliver, manage and improve our services, to invoice and manage our accounts, and to keep records. Lawful basis: performance of a contract (where you or your organisation contract with us); our legitimate interests in delivering services to our client organisations and keeping proper records; and legal obligation (for example tax and accounting records).
2.3 360° assessments and analytics
Some of our programmes use 360° leadership assessments, including those provided through our strategic partner Zenger Folkman. Depending on the engagement, this may involve personal data about the leader being assessed (name, role, email, assessment results and reports) and about the people who provide ratings and comments (name, email, relationship to the leader, and their responses). The way ratings are collected, anonymised and reported is explained to participants before an assessment begins. Why: to provide evidence-based feedback and measure development progress. Lawful basis: performance of a contract and our legitimate interests in delivering the assessment service. Where the assessment platform is operated by Zenger Folkman, it may act as our processor or as an independent controller of the data it collects; its own privacy notice will apply to that processing.
2.4 Business contacts and marketing
What: name, business email address, organisation and role, and records of our communications. Why: to keep in touch about our services, articles and events, and to build professional relationships. Lawful basis: our legitimate interests in promoting our business to relevant organisations, or your consent where the law requires it (for example, for marketing emails to individual subscribers such as sole traders and some partnerships). You can opt out of marketing at any time by using the unsubscribe link or emailing us. We will stop straight away.
2.5 Website usage data and cookies
What: IP address, browser and device type, pages viewed, referring site, and similar technical information collected through cookies and similar technologies. See section 9. Why: to keep the Website secure and working, and to understand how it is used so we can improve it. Lawful basis: our legitimate interests for strictly necessary technologies; your consent for non-essential cookies and similar technologies.
2.6 Special category data
We do not ask you for special category data (such as information about your health, ethnicity or beliefs). If you choose to share it with us, for example in a coaching conversation, we will only use it where you have given explicit consent or another condition in data protection law applies, and we will treat it with particular care.
3. Where we get your data from
Mostly directly from you. We also receive data from your employer or organisation (where we deliver services to them), from assessment platforms and raters (see 2.3), and from publicly available professional sources such as LinkedIn.
4. Who we share your data with
We do not sell your personal data. We share it only with:
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Website and hosting provider: Wix.com Ltd and its group companies, which host the Website, process contact form submissions and provide site analytics.
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Assessment partners: Zenger Folkman, for 360° assessments and analytics.
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Service providers: providers of email, cloud storage, video conferencing and scheduling that we use to run the business, and our business bank, Tide.
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Professional advisers: our accountants, Vantage Accounting, and any insurers, lawyers or similar advisers, under duties of confidentiality.
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Authorities: where required by law, court order or to protect legal rights.
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Business transfer: a successor if our business is sold or restructured, on the basis that your data continues to be protected.
Where a provider handles data on our behalf, we require it to do so only on our instructions and to keep it secure.
5. International transfers
Some of our providers (including Wix and Zenger Folkman) may process data outside the UK, including in the United States and Israel. Where they do, we rely on appropriate safeguards under UK data protection law, such as UK adequacy regulations, the UK-US data bridge for certified recipients, or the UK International Data Transfer Agreement or UK Addendum to the EU Standard Contractual Clauses. You can contact us for more information about these safeguards.
6. How long we keep your data
We keep personal data only as long as we need it for the purposes above. Our current periods are:
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Enquiries that do not lead to work: up to 12 months after our last contact.
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Client, contract and invoicing records: 6 years after the end of the relevant financial year or engagement, to meet tax, accounting and contract-limitation requirements.
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Coaching, workshop and assessment records: 2 years after the engagement ends, unless the client agreement says otherwise.
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Marketing contacts: until you unsubscribe or ask us to delete your details, and we review these lists regularly.
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Website analytics and cookies: for the periods set out by the relevant cookie.
After these periods we delete or anonymise the data.
7. Security
We use appropriate technical and organisational measures to protect personal data, including access controls, encrypted connections (HTTPS) and reputable providers. No system is completely secure. If a personal data breach is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office within 72 hours, and we will tell you where the law requires.
8. Your rights
Under UK data protection law you have the right to:
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be informed about how we use your data (this policy);
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access a copy of the personal data we hold about you;
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have inaccurate data corrected;
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have your data erased in certain circumstances;
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restrict our processing in certain circumstances;
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receive your data in a portable format, where processing is based on consent or contract and carried out by automated means;
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object to processing based on legitimate interests, and to direct marketing at any time; and
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withdraw consent at any time, where we rely on consent (this does not affect processing already carried out).
To exercise any of these rights, email jonathanbowder@theswitchlab.co.uk. We may need to verify your identity. We will respond within one month, which we may extend by up to two further months for complex or numerous requests, and we will tell you if so. There is normally no charge.
We do not carry out solely automated decision-making or profiling that has legal or similarly significant effects on you.
9. Cookies and similar technologies
The Website is built on Wix. Cookies and similar technologies are small files or scripts placed on your device.
Based on the apps currently installed on the Website, it uses essential cookies only. These are placed automatically by the Wix platform to make the Website work and keep it secure and stable — for example, recognising your session, protecting against fraud and attacks, remembering your progress through a form or booking, and remembering settings as you move between pages. Essential cookies do not require your consent. We do not currently have a separate marketing, advertising or analytics tool (such as Google Analytics or a Facebook/Meta pixel) installed on the Website.
If the Website displays a cookie banner, it lets you accept or decline any non-essential cookies; you can also control cookies at any time through your browser settings. Blocking some cookies may affect how the Website works. Wix publishes a fuller, regularly updated list of the cookies its platform uses on its own site.
We will update this section if that changes — for example, if we add analytics or marketing tools in future.
10. Links to other websites
The Website links to other sites, including LinkedIn and Zenger Folkman. We are not responsible for their content or privacy practices, so please read their own privacy notices.
11. Children
The Website and our services are aimed at businesses and working adults. We do not knowingly collect personal data from children under 18. If you believe a child has given us personal data, please contact us and we will delete it.
12. Complaints
If you are unhappy with how we have handled your personal data, please contact us first at jonathanbowder@theswitchlab.co.uk so we can try to put it right. We aim to acknowledge complaints within 30 days and to respond without undue delay.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK data protection regulator:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Telephone: 0303 123 1113 Website: ico.org.uk
13. Changes to this policy
We may update this policy from time to time. The "last updated" date above shows when it was last changed. Where changes are significant, we will take reasonable steps to let you know.
