Cookie policy

Last updated: 9 July 2025

Emphasis Limited (“we” or “us” or “our”) may use cookies, web beacons, tracking pixels, and other tracking technologies when you visit our website www.emphasis.uk.com, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “site”) to help customise the site and improve your experience.

We reserve the right to make changes to this cookie policy at any time and for any reason. We will alert you about any changes by updating the “last updated” date of this cookie policy. Any changes or modifications will be effective immediately upon posting the updated cookie policy on the site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to review this cookie policy periodically to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised cookie policy by your continued use of the site after the date such revised cookie policy is posted.

Use of cookies

A “cookie” is a string of information that assigns you a unique identifier, which we store on your computer. Your browser then provides that unique identifier to use each time you submit a query to the site. We use cookies on the site to, among other things, track the services you have used, record registration information, store your user preferences, keep you logged in to the site, facilitate purchase procedures, and monitor the pages you visit. cookies help us understand how the site is being used and improve your user experience.

If you have questions or comments about this cookie policy, please get in touch with us at:

Emphasis Limited
Lone Barn Studio 3, Stanbridge Lane, Romsey, SO51 0HE
Tel: 01794 874232
Email: hello@emphasis.uk.com

Client privacy notice 

Data controller: Becky Watton, Director of Emphasis Limited – Becky@emphasis.uk.com 

What is the purpose of this document? 

Emphasis Limited is a third party “data controller”.  In relation to you and your employees’ personal data, this means Emphasis employees process data on your behalf as the third party data controller.   

You are receiving this privacy notice because you have engaged Emphasis Limited in one of the following capacities: 

• As a training client 

• By purchasing a psychometric profile 

• Or by using our services on a retained, project-based, or ad-hoc basis 

We are writing to make you aware of how and why you and your employees’ personal data will be used; namely for the purposes of dealing with employment issues, and how long it will usually be retained for.  It provides you with certain information that must be provided under the UK General Data Protection Regulations (UK GDPR). 

Data protection principles  

We will comply with data protection law and principles, which means the data we process on your behalf as the data controller will be: 

• Used lawfully, fairly and in a transparent way 

• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes 

• Relevant to the purposes we have told you about and limited only to those purposes 

• Accurate and kept up to date 

• Kept only as long as necessary for the purposes we have told you about 

• Kept securely. 

What information do we collect? 

In connection with your instructions, we will collect, store, and use the following categories of personal information about you and your employees: 

• The information you provide to us in relation to your employees 

• Information provided directly from employees 

• Names, titles, addresses, telephone numbers, email addresses, dates of birth, gender, employment history, qualifications etc 

• Any information provided to us either by you, the employer, or directly from your employees during the course of working with you including information provided by other sources (e.g. ex-employers, occupational health, psychometric profiling tools). 

We may also collect, store and use the following “special categories” of more sensitive personal information during the course of working with you: 

• Information about employee’s race or national or ethnic origin, religious, philosophical or moral beliefs, sexual orientation or and trade union membership 

• Information about employee health, including any medical condition, health and sickness records 

• Information about employee criminal convictions and offences 

How do we collect the personal data? 

We collect personal information about employees from the following sources: 

• You, as the employer 

• Directly from the employee 

• Employment solicitors 

• Occupational health provider, medical advisers / payroll provider 

• HR information systems  

• Psychometric profiling tools (such as Thomas International and Insights Discovery)

How will we use the information? 

We will use the personal information we collect about you and your employees to: 

• Enable us to act on your behalf and provide employment advice to you 

• Comply with legal or statutory requirements 

If you do not provide personal information 

If you do not provide information when requested, which is necessary for us to carry out our services, we may not be able to continue to act for you. 

How will we use particularly sensitive personal information? 

We will use your particularly sensitive personal information in the following ways in the course of working with you, if appropriate: 

• We will use any information about an employee’s disability status to advise you 

• We will use any information about sickness or mental health to advise you and/or the employee on possible reasonable adjustments to their working hours, environment or roles 

• We will use information about an employee’s race or national or ethnic origin, religious, philosophical or moral beliefs, or sexual orientation to work with you on equality issues 

Information about criminal convictions 

We do not envisage we will ordinarily process information about criminal convictions of your employees unless raised by you or another party in the course of working with you or if raised during the recruitment process. 

However, we will collect information about their criminal convictions history if we think it will be relevant to your employment matter. 

Automated decision-making 

You and your employees will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.  

Why we might share your personal information with third parties?  

We will only share the personal information of your employees with third parties for the purposes of furthering your instructions: for example, we may send your details to an employment solicitor to obtain their opinion on your matter.  We may need to share with a barrister or ACAS conciliator if they are involved in any Employment Tribunal proceedings.  We may also need to share information with an Occupational Health professional or obtain a medical opinion from GPs, Consultants or other medical advisors.  All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies.  We do not allow our third-party service providers to use your personal data for their own purposes.  We only permit them to process your personal data for specified purposes and in accordance with our instructions.  We would always notify you prior to sharing any employee information with third parties. 

Data security  

We have put in place appropriate security measures to prevent the personal information of employee from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know.  They will only process the personal information on your instructions and they are subject to a duty of confidentiality.  

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.  

How long will you use my information for? 

We will retain your personal information up to a period of one year (or longer where appropriate to do so or where you give us permission to do so).  To comply with relevant legislation and to deal with matters arising concerning that information/your case and to deal with further issues on your employment matter we may have to keep the information for longer.  We also retain it to deal with complaints and appeals.    

What if I don’t want to share my information or my employee’s information? 

We may be unable to work for you if you do not consent to us retaining the personal information on you and your employees during that one year period.  By signing the acknowledgment declaration at the end of this Privacy Notice, you consent to us retaining the personal information during the one year period. 

Email confidentiality and active deletion  

Email correspondence between you and Emphasis Limited does not possess legal privilege and, as such are subject to disclosure under subject access requests. To ensure the confidentiality and security of sensitive information, Emphasis Limited operates a policy and procedure for the active deletion of emails containing confidential data as summarised below. 

Identification of confidential emails: Emails containing sensitive information such as personal data, financial information, proprietary information, or any other confidential data must be identified and flagged for deletion once the task is closed or after the retention period. 

Retention period: Confidential emails should be retained only for the duration necessary to complete the relevant task or transaction. Once the task is completed, the email must be deleted within 30 days.  

Deletion procedures: Users manually delete confidential emails from their inbox, sent items, and any other folders. Deleted emails must also be removed from the “Deleted Items” or “Trash” folder to ensure complete removal.  

Automated deletion: Emphasis Limited have automated deletion protocols on inboxes to ensure that emails moved to the “Deleted Items” or “Trash” folder are deleted at the end of the day.  

Compliance and monitoring: Regular monitoring will be conducted to ensure compliance with this policy. 

Employee rights in connection with personal information held by Emphasis Limited 

Under certain circumstances, by law you and your employees have the right to: 

• Request access to their personal information (commonly known as a “data subject access request”).  This enables them to receive a copy of the personal information we hold about them and to check we are lawfully processing it 

• Request correction of the personal information we hold about them.  This enables them to have any incomplete or inaccurate information we hold about them corrected 

• Request erasure of their personal information.  This enables them to ask us to delete or remove personal information where there is no good reason for us continuing to process it.  They also have the right to ask us to delete or remove their personal information where they have exercised their right to object to processing (see below) 

• Object to processing of their personal information where we are relying on a legitimate interest (or those of a third party) and there is something about their situation which makes them want to object to processing on this ground.  They also have the right to object where we are processing their personal information for direct marketing purposes. 

• Request the restriction of processing of their personal information.  This enables them to ask us to suspend the processing of personal information about them, for example if they want us to establish its accuracy or the reason for processing it 

• Request the transfer of their personal information to another party 

If employees want to review, verify, correct or request erasure of their personal information, object to the processing of their personal data, or request we transfer a copy of their personal information to another party, please contact us in writing. 

Right to withdraw consent 

Emphasis is a third party data processor and therefore acts on behalf of you, the employer and data controller.  You have the right to withdraw your consent for processing your employees’ data for the purposes outlined above at any time.  To withdraw your consent, please contact us.  Once we have received notification that you have withdrawn your consent, we will no longer process your employees’ data and, subject to our retention policy, we will dispose of all your employee data securely.