Privacy Policy
Last updated: October 2025
1. Introduction
Fletcher Oakmont Limited (“we”, “us”, “our”) respects your privacy and is committed to protecting your personal information.
This Privacy Policy explains how we collect, use, store and share personal information when you visit our website, contact us, complete a People Readiness Index™ assessment, or use our diagnostic, HR consultancy and training services.
Fletcher Oakmont Limited is registered in England and Wales under company number 16686549, with its registered office at 19a Lydwell Road, Torquay, TQ1 1SN.
We are the data controller for personal information we use to manage our website, enquiries, client relationships and business operations.
Where we process personal information on a client’s behalf and under their instructions, we act as a data processor. In those circumstances, the client’s privacy notice and our contractual arrangements also apply.
2. Information We Collect
Depending on how you interact with us, we may collect:
Contact and business information: your name, email address, telephone number, job title and organisation.
Enquiries and correspondence: information you provide through forms, emails, meetings or other communications.
Assessment information: People Readiness Index™ responses, participant details, feedback and information used to prepare reports and recommendations.
Service information: documents and information supplied in connection with HR advice, consultancy, training or other agreed services.
Transaction information: billing details, invoices and payment records.
Marketing preferences: your subscription choices and records of consent or objections.
Technical information: your IP address, browser and device information, pages visited and interactions with our website, where collected through our website systems or permitted cookies.
We may receive information directly from you or from your employer, colleagues, a commissioning organisation or an authorised representative in connection with our services.
PRI assessments concern organisational practices. Please do not include names or identifiable information about individual employees, care recipients or other people unless we specifically request it through an appropriate process.
HR consultancy work may require employee information, including sensitive information such as health information. We only process this where necessary for the agreed work and subject to the applicable legal requirements and contractual arrangements.
3. How We Use Your Information
We use personal information to:
Respond to enquiries and discuss potential services.
Deliver assessments, reports, debriefs, HR advice, consultancy and training.
Manage client relationships, appointments, contracts and payments.
Provide agreed follow-up support and progress reviews.
Gather feedback and improve our services.
Produce agreed programme reporting and organisational comparisons.
Send updates and marketing communications in accordance with your preferences and applicable law.
Operate, maintain and protect our website and business systems.
Meet legal obligations and establish, exercise or defend legal claims.
Where possible, we use anonymised information for benchmarking, trend analysis and service development. Information is only treated as anonymous where individuals can no longer reasonably be identified.
4. Our Legal Bases for Processing
Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as amended, we rely on:
Legitimate interests: to respond to business enquiries, manage client relationships, deliver services to organisations, improve our services and protect our business, where these interests do not override your rights.
Contract: where processing is necessary to enter into or perform a contract with you personally.
Consent: where you agree to receive marketing communications or where consent is required for particular cookies or other processing.
Legal obligation: where processing is necessary to meet our legal responsibilities.
Where we process special category information as a controller, we also identify an appropriate additional legal condition. Depending on the circumstances, this may include processing necessary for employment law obligations or establishing, exercising or defending legal claims.
Where we act as a processor, we process information under the client’s documented instructions and the relevant data processing agreement.
5. PRI Assessments and Programme Reporting
We use PRI responses to assess organisational readiness and prepare scores, reports, recommendations and debrief discussions.
Where an assessment forms part of a programme commissioned by a head office, franchise network or other organisation, we explain the reporting arrangements before collecting responses. This includes whether the commissioning organisation will receive identifiable organisation-level results, individual reports or aggregated findings.
We do not assume that participation gives unrestricted permission to share personal information or confidential consultancy discussions.
PRI scoring assesses organisational practices. It is not intended to make solely automated decisions about individuals that have legal or similarly significant effects.
6. Sharing Your Information
We do not sell or rent your personal information.
Where necessary, we may share it with:
Service providers supporting our website, email, online forms, document storage, business administration, payments and service delivery.
Authorised associates or subcontractors involved in delivering agreed services, subject to appropriate confidentiality and data protection arrangements.
Professional advisers, including accountants, insurers and legal advisers.
A commissioning organisation or authorised client contacts, in accordance with the reporting arrangements explained for the relevant service.
Regulators, public authorities or other parties where disclosure is required by law or necessary to establish, exercise or defend legal claims.
We limit sharing to what is necessary and use appropriate contractual protections where required.
7. International Transfers
Some technology providers may store or access personal information outside the UK.
Where this involves a restricted international transfer, we ensure that an appropriate legal mechanism applies. This may include UK adequacy regulations or approved contractual safeguards, together with any required assessment and additional protections.
You can contact us for further information about the safeguards relevant to your information.
8. How Long We Keep Information
We retain personal information only for as long as reasonably necessary for the purpose for which it was collected.
Retention depends on the type of information, the services provided, contractual requirements, legal obligations and any need to deal with complaints or legal claims.
In particular:
Enquiries: retained while we deal with your enquiry and for a reasonable follow-up period.
Client and service records: retained for the engagement and an appropriate period afterwards to support continuity, respond to queries and meet contractual or legal requirements.
PRI records: retained where needed for agreed reporting, progress reviews and reassessment.
Financial records: retained for the periods required by applicable tax and accounting law.
Marketing records: retained until you unsubscribe or we determine that they are no longer needed. We may retain a minimal suppression record to ensure that we respect your request.
Where we process information on a client’s behalf, its return or deletion is governed by our agreement with that client.
Information is securely deleted or anonymised when it is no longer required.
9. Data Security
We use appropriate technical and organisational measures to protect personal information against unauthorised access, disclosure, alteration, loss or destruction.
Access is limited to people and service providers who need it for authorised purposes and who are subject to appropriate confidentiality obligations.
No online system can be guaranteed completely secure. If a personal data breach occurs, we will assess it and meet any applicable notification requirements.
10. Cookies and Similar Technologies
Our website and embedded services may use cookies or similar technologies to support functionality, remember preferences and understand website usage.
Where consent is legally required, we will ask for it before placing or accessing those technologies. You can withdraw consent through the available cookie controls.
Your browser also allows you to manage or delete cookies, although blocking some cookies may affect website functionality.
Details of the technologies in use, their purposes, providers and durations should be available through our website’s cookie information and controls.
11. Marketing Communications
Where you subscribe to our updates, we use your contact details to send relevant HR news, insights and information about our services.
You can unsubscribe at any time by:
Using the unsubscribe link, where provided.
Emailing hello@fletcheroakmont.co.uk.
Unsubscribing from marketing does not prevent us from sending necessary communications about services you have requested or purchased.
12. Your Rights
Depending on the circumstances, you have the right to:
Request access to your personal information.
Ask us to correct inaccurate or incomplete information.
Request deletion of your information.
Ask us to restrict its use.
Object to processing based on legitimate interests.
Receive certain information in a portable format.
Withdraw consent where we rely on it.
You can object to the use of your personal information for direct marketing at any time.
These rights are subject to applicable conditions and exemptions. Withdrawing consent does not affect the lawfulness of processing carried out beforehand.
To exercise your rights, email hello@fletcheroakmont.co.uk. We normally respond within one month, subject to any lawful extension. We may need to verify your identity before responding.
Where we hold information solely on a client’s behalf, we may refer your request to that client and assist them in responding.
13. Complaints
If you have concerns about how we handle your personal information, please contact us at hello@fletcheroakmont.co.uk.
You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s data protection regulator:
Website: www.ico.org.uk/make-a-complaint
14. Changes to This Policy
We may update this Privacy Policy to reflect changes to our services, practices or legal obligations.
The latest version will be published on this page with an updated date. Where required, we will bring significant changes to your attention.
15. Contact Us
Fletcher Oakmont Limited
Email: hello@fletcheroakmont.co.uk
Registered office: 19a Lydwell Road, Torquay, TQ1 1SN
Company number: 16686549