Data, privacy and use of AI

This page explains how we collect, use and protect your data, and how we use artificial intelligence in our work. The two sit together because, for us, they are part of the same commitment to treating you, our work together, and your information with respect.

1.0 Our core beliefs regarding client and user privacy and data protection

Trust is key to the relationships we have with our clients and their people and the work we do together. That’s one reason for us to treat your data with the respect it deserves. Another is that it’s simply the right thing to do. This policy outlines how we treat your data, whether that’s when you’re using this website or when you’re working with us.

In everything we do, we seek to model the three ARC Qualities at the heart of Richard’s work: authenticity, responsibility and courage. Where data is concerned, this means:

• We believe we have a duty of care to the people whose data we hold
• We believe in knowledge as a force for good, not a means of manipulating others for personal or commercial gain – hence we will never sell, rent or otherwise distribute or make public your personal information
• We loathe spam as much as you do
• We believe it’s important to share new ideas, particularly those from outside one’s own ‘echo chamber’

2.0 Relevant legislation

We endeavour to comply with the following national and international legislation with regards to data protection, user privacy and AI:

• • The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025
• • The EU General Data Protection Regulation (GDPR), where it applies to the people we work with in the European Union
• • The EU AI Act (2026) and applicable requirements in the United States

We’re based in the UK. Where we work with people in the EU, we hold to the EU GDPR, and more generally we continue to subscribe to the spirit and standards of that legislation, all of which are stringent in nature. Our compliance with the above means this site is likely to be compliant with the data protection and user privacy legislation set out by many other countries and territories as well.

The data we collect in the course of our work is more sensitive. We’ll cover that in Section 4.

3.0 Personal information our website collects, why we collect it and your rights with regard to that data

This website collects and uses personal information for the following reasons:

3.1 Measuring the use and effectiveness of this website

Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.

Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you. However, Google do not grant us access to this. We consider Google to be a third-party data processor (see section 6.0 below).

GA and this website use cookies, which are small text files that are placed on your computer by websites that you visit. These are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage, disable and delete them, visit www.allaboutcookies.org.

The cookie set by Google Analytics is _ga, which expires after 2 years. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

This website also uses the following cookies, which are built in by WordPress, the application through which this website is built and updated:

• X-mapping-kjicghkc – a load-balancing cookie, and helps to optimise the performance of the site. It contains a random number and expires at the end of your session
• wordpress_test_cookie, which expires at the end of the session
• wp-settings-1, which expires after 1 year
• wp-settings-time-1, which expires after 1 year
• _atuvc – a cookie used by AddThis, an app built into this website that enables you to share pages on the site with other people via popular social media websites. This cookie expires after 2 years

3.2 Contacting you with things we genuinely believe you’ll find useful

When it comes to email marketing, we’ve never believed in simply uploading all of our contacts to a database and spamming all and sundry. We only ever send automated emails to people who have knowingly signed up to a mailing list. Should you request free chapters from Richard Boston’s books or access to the Resources offered on our website to support you as a reader of Richard’s books, the data that you submit to us will be forwarded from the website to our internal computer system to facilitate communication with you.

The data we ask you for helps us understand who is using the resources on our website and to tailor them accordingly. It also helps us exclude you from any mailings if those mailings are unlikely to appeal to someone in your position or industry.

While your email address remains on our system database, you will receive occasional newsletter-style emails from us. We don’t believe in frequently bombarding you with stuff that’s no use to you. So we will email you intermittently with news, links to blogs and alerts when new books come available. Our intention is to do so no more than three times a year, but we’ll most likely do it even less often than that.

If you are under 16 years of age you MUST obtain parental consent before signing up for this content.

3.3. Your right to access and control your personal information

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by emailing us at hello@leaderspace.com

Please contact us in the same way if you require details of the personal information which we hold about you, or if you believe any information we are holding on you is incorrect or incomplete.

3.4 Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

4.0 How we store individual client data

As psychologists and coaches, we take notes during the course of our work as those notes help us deliver on the work we’re contracted to do. These are stored in one or both of two places: on paper and on computers. Notes held on paper are stored in a locked cabinet when not in use, and shredded or burned on site when the time comes to destroy them. Those held electronically are stored on computers protected by passwords, antivirus software and encryption – details of which are available by contacting us directly. The British Psychological Society advises that client notes be kept for seven years. Given the nature of our relationships with client organisations, we keep records for those seven years or until our work with the organisation in question ends, whichever is later. So if you wish for your records to be destroyed prior to that, please let us know in writing using the details below.

4.1 Security

Where files are synchronised across devices or stored in the cloud, they are encrypted using a minimum of TLS and AES 256-bit encryption, with much of our data also encrypted at source. Our policy is to never send psychometrics via email without the recipient’s prior written permission, and even then these will be password-protected. If your coach sends you ‘reflective feedback’ documents, then these will be password protected, with the password provided by some other medium (usually WhatsApp). Individual client data is never stored or transported between sites on USB sticks or similar portable media.

If you are sending reflective feedback to us, then we recommend you also password-protect the document and send the password via WhatsApp.

4.2 Psychometrics and other online questionnaires

We use a range of providers. It is our understanding that all of them are GDPR compliant.

As discussed in section 4.1, the vulnerabilities of email security mean that we will not send psychometric reports by email without your prior written permission, and they will be password-protected.

We sometimes use SurveyMonkey to run team diagnostics and other questionnaires. To use the language of GDPR, in most respects, LeaderSpace is the data controller of the responses you give to those questionnaires. SurveyMonkey is the data processor. Exceptions – where SurveyMonkey is the data controller – include cookie data and your IP address, used for specific purposes as described in SurveyMonkey’s own Privacy Policy (https://www.surveymonkey.com/mp/legal/privacy-policy/). Our policy is for the LeaderSpace consultant in question to download the survey response data to their computer once each survey is closed. We then delete that data from SurveyMonkey’s platform within one month – we leave it there for that time in case the data we have becomes corrupted for some reason. It is our understanding that that data is simultaneously removed from their servers. We have no access to the data they collect as data controllers themselves – the cookies, etc.

4.3 Contact details

Naturally, each member of the team holds the names and contact details of their clients and other contacts. We do not keep a central database of everyone’s contacts. However, for specific projects we may share the contact details of participating individuals and key stakeholders. We will only do so when this is necessary for project-related communications with those people.

4.4 Sharing other information about you

When two or more LeaderSpace consultants are working together with the same participants, we often compare notes to help us coach more effectively. If this is the case, this will always be made clear to all participants. Technically, as we use an associate model, some of our consultants are not LeaderSpace employees. However, we need to treat them as staff to provide the level of service our clients expect. Thus, each of them signs up to this data protection policy as part of their contract with us and the information we share with them is limited to the projects on which they are working.

Our default is that we do not share personal client information with other third party organisations. The only exceptions to this rule are as follows:

• When an individual client’s employer asks for attendance data
• When generating certain MBTI (psychometric) reports, we may be required to enter the client’s ‘best fit’ MBTI type – thus we are ‘sharing’ that data with the publisher of the MBTI
• When including participants in emails to fellow participants and/or the commissioning client (i.e. the organisation paying for our services)
• When the team member working with you is operating in a freelance capacity, in which case they will be required to adhere to the same policies as LeaderSpace
• When the individuals have given their express permission
• When quoting feedback anonymously to give other clients and potential clients a feel for our work – where possible, we would seek permission to use these quotes and we will always take care to ensure anonymous feedback is truly anonymous
• During coaching supervision, where the ‘data’ is spoken and not recorded
• When we are required to do so by law

4.5 Your rights

The following individual rights under GDPR apply to the data we hold:

• The right to be informed
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to object
• The right not to be subject to a solely automated decision that produces legal or similarly significant effects, including certain profiling

The right to data portability applies only to personal data you have actively provided to us, where we process it by automated means on the basis of your consent or a contract – for example, mailing-list details, or your responses to a team diagnostic we run ourselves. It does not extend to the professional notes and observations our coaches record, nor to reports generated from your responses to psychometric questionnaires provided by our suppliers. We have no access to your responses to those questionnaires, so if you would like access to those, you would need to request it from the supplier(s) who administered the questionnaire(s). You can, however, request a copy of any report we hold about you under your right of access, and we will provide it subject to the limited exceptions in 4.6. Where we use automated processing, including AI tools, we do not use it to make solely automated decisions that have a legal or similarly significant effect on you: a named person remains responsible for every significant decision, as stated in section 7.3 below.

4.6 Your right to access this data

The size of our business and the nature of this data means we may need to make a small charge if you request the data. On some occasions, we may be unable for legal or ethical reasons to share some of the data we might hold. The clearest examples are where we are privy to sensitive management information or references / feedback provided in confidence by others. Under the GDPR, this kind of data is protected if it is judged likely to “prejudice the business or other activity of the organisation”.

5.0 Data breaches

We will report to the ICO and any and all relevant persons and authorities any unlawful data breach of our website’s database, our computers or our paper-based storage within 72 hours of the breach, if it is apparent that personal data stored in an identifiable manner has been stolen. If the breach pertains to the database(s) of any of our third-party data processors we will take the same action within 72 hours of them notifying us of such a breach.

6.0 Data controller

The data controller for this website and all activities conducted by LeaderSpace Ltd, is LeaderSpace Ltd, UK company number 6591839.
Flat 11 Clifton Down Mansions, Bristol BS8 2XJ.
hello@leaderspace.com

According to the ICO, the nature of our business and scale of our operations mean there’s no need for a dedicated Data Protection Officer. If you have any questions or concerns, please contact our Managing Director, Richard Boston.

7.0 Our use of AI

At the time of writing, the world’s use of artificial intelligence is swiftly evolving, and we want to be straight about how we use it. As with your data, we try to bring the three ARC Qualities at the heart of Richard’s work to this topic: authenticity, responsibility and courage. The following commitments shape what we do.

7.1 AI enhances our work; it doesn’t replace the people who do it

We believe this technology should enable people and organisations to do things they couldn’t do otherwise, not make them redundant. So, we use AI to enhance our efficiency, creativity and rigour, but we don’t use it to quietly remove the human thinking, judgement and relationship.

7.2 We keep identifiable individual data out of AI tools

We don’t put information that directly identifies individuals into AI tools. Where we use AI to help us work with assessment outputs such as psychometric reports, we strip out the direct identifiers first and handle what remains under the data commitments set out below. The cleanest way to protect your data from a still-maturing technology is to expose as little of it as possible, and never the parts that name you.

7.3 A human stays responsible for every significant decision

AI might help us prepare, draft, analyse, critique or flesh out our evidence base, but it does not make the calls. The significant judgements in our coaching, consulting and programme design rest with a named person who is accountable for them.

7.4 We check what AI tells us

We treat a confident AI answer as a starting point, not a conclusion, and we verify facts and sources against reputable, named references before relying on them. In fairness, applying that discipline has made us wonder whether the sources behind human assertions have ever been held to the same standard. We think AI is a good reason to raise that bar for everyone, ourselves included.

7.5 We flag the use of AI where it matters

AI has quietly become as ubiquitous as Microsoft Office, search engines and email, and like those tools it now sits behind a great deal of ordinary work. So, we don’t feel the need to name each instance of using it any more than anyone names the software they used to draft a document. But where it genuinely matters we’ll tell you – for instance, where AI has been used to summarise a body of data. And where the law requires disclosure, of course we will do so.

7.6 We won’t yet fully commit to a single tool

This technology is fairly new and won’t settle for quite some time. Tools will come and go, and access to certain tools may be restricted to certain geographies. So, for the time being, we are experimenting with various tools. In addition, some of our work is delivered by experienced associates who will have their own preferences. In all cases, though, whenever they work with us, they are bound by these commitments in full, exactly as they are by the privacy policy above. We also endeavour to role-model best practice, in the hope that they’ll apply this same rigour across their use of AI.

7.7 We will evolve our policies to role-model best practice as best we can

We are a small company, but our work has a marked impact on how much larger organisations operate. So, we aim to set an example for Authentic, Responsible and Courageous use of this emerging technology.

8.0 Changes to our privacy policy

This privacy policy may change from time to time in line with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the change log below.

8.1 Change Log

May 2018: updated to reflect GDPR.
June 2019: updated to reflect our evolving practice and ongoing risk assessments with regard to data protection.
August 2019: updated to include references to SurveyMonkey’s data policies.
January 2021: updated to reflect the end of the transition period for the UK’s exit from the European Union.
February 2023: updated to include references to ‘reflective feedback’ and the change to our registered company address.
July 2026: added our policy on the use of AI, and updated the relevant legislation in Section 2.0 to reflect the Data (Use and Access) Act 2025.