Privacy Notice
Last updated: 26 July 2026
About this notice
Divergent Training Ltd, trading as Divergent Thinking, is the controller responsible for the personal information described in this notice. We are registered in England and Wales under company number 14074540. Our registered office is 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.
This notice explains how we collect, use, share and protect personal information when you visit our website, make an enquiry, book or attend our services, work with us as a client or supplier, or apply for a role.
Information we collect
Depending on how you interact with us, we may collect:
• identity and contact details, such as your name, job title, organisation, email address and telephone number;
• enquiry, booking, contract and correspondence details;
• payment, invoicing and transaction records;
• attendance, feedback, testimonial and event information;
• technical and usage data, such as IP address, device, browser, pages visited and cookie preferences;
• recruitment information, such as a CV, work history and reasonable-adjustment needs; and
• accessibility or adjustment information that you choose to provide.
We usually receive information directly from you. We may also receive it from your employer or commissioning organisation, event partners, publicly available professional sources, referral partners and the service providers that support our website and business systems.
How and why we use personal information
We use personal information only where we have a lawful basis. This may include:
• taking steps at your request before entering a contract and performing our contract with you or your organisation;
• responding to enquiries, managing client relationships, improving our services, maintaining appropriate business records and protecting our services, where this is necessary for our legitimate interests and those interests are not overridden by your rights;
• meeting legal, tax, accounting, safeguarding and regulatory obligations;
• sending optional marketing where you have consented, or where another lawful electronic-marketing rule applies, with an unsubscribe option in every message; and
• using non-essential cookies and similar technologies only after you have given consent.
Sensitive information and reasonable adjustments
Information about health, disability or neurodivergence may be special-category personal data. We ask only for information that is needed to make our services accessible, safe and suitable. We use it with your explicit consent or, where applicable, another condition permitted by data-protection law. Please do not send detailed diagnostic or medical records unless we specifically explain why they are required. You may withdraw consent at any time, although this will not affect processing that was lawful before withdrawal.
Cookies, analytics and marketing technologies
Our site uses essential technologies needed for security and basic operation. With your permission, it may also use analytics and marketing technologies, including Google Analytics, Microsoft Clarity and Meta technologies, to understand site use and measure communications. Non-essential technologies should not be set before you consent. You can accept, reject or change your choices through the cookie settings shown on the site. Blocking some technologies may affect optional features but should not prevent basic access to the site.
Who we share information with
We share personal information only where necessary. Recipients may include:
• website, hosting, communications, scheduling, cloud-storage, CRM, accounting, payment and analytics providers acting under appropriate terms;
• a commissioning organisation where it has arranged a service, but only to the extent agreed and appropriate;
• professional advisers, insurers, auditors and regulators; and
• public authorities or other parties where disclosure is required by law or needed to establish, exercise or defend legal claims.
We do not sell personal information. We do not provide an employer or commissioning organisation with confidential coaching or adjustment details unless you have agreed to that disclosure or the law requires it.
International transfers
Some suppliers may process information outside the United Kingdom. Where this happens, we use an applicable adequacy decision or approved safeguards, such as the UK International Data Transfer Agreement or the UK Addendum to standard contractual clauses, together with any necessary risk assessment. You can contact us for more information about the safeguards relevant to your data.
How long we keep information
We keep information only for as long as needed for the purpose collected, including legal, accounting and safeguarding requirements. Our usual periods are:
• contracts, proposals and statements of work: six years after the project;
• finance and transaction records: six years after the relevant accounting period;
• attendance lists: up to 12 months;
• adjustment and access requests: normally three months after delivery, unless ongoing support requires longer;
• session recordings: normally 12 months, unless a contract specifies otherwise;
• prospect and CRM records: reviewed at least annually, with stale information deleted or minimised;
• named testimonials: reviewed at least annually and removed if permission is withdrawn; and
• anonymised feedback: may be retained for trend and service-improvement evidence where it no longer identifies an individual.
We may keep information longer where there is a complaint, legal claim, safeguarding concern or another lawful reason. When it is no longer required, we delete, anonymise or securely dispose of it.
Security
We use proportionate organisational and technical safeguards, including access controls, secure service providers, staff procedures and data minimisation. No internet service can guarantee absolute security. If we identify a personal-data breach, we assess it promptly and notify affected people and the Information Commissioner's Office where required.
Your rights
Depending on the circumstances, you may have the right to:
• be informed about how your information is used;
• request access to it;
• correct inaccurate or incomplete information;
• ask for deletion or restriction;
• object to processing based on legitimate interests or to direct marketing;
• receive certain information in a portable format;
• withdraw consent at any time; and
• ask for human review of a qualifying automated decision.
These rights are not absolute and exemptions may apply. To exercise a right, email nat@divergentthinking.uk. We may need to confirm your identity. We normally respond within one month, or explain if the law permits more time.
Complaints
Please email nat@divergentthinking.uk if you have a data-protection concern. We will acknowledge a formal complaint within 30 days and investigate and respond without undue delay, keeping you informed where appropriate.
You also have the right to complain to the Information Commissioner's Office at ico.org.uk or by calling 0303 123 1113. We would welcome the opportunity to address your concern first, but this does not affect your right to contact the ICO.
Children
Our services and website are aimed at organisations and adults, not children. Where a service involves children or young people, we agree appropriate safeguarding and data-handling arrangements with the commissioning organisation and, where required, the person with parental responsibility.
Automated decision-making and AI
We do not make decisions about people using solely automated processing that produces legal or similarly significant effects. If this changes, we will explain the logic, significance, consequences and available safeguards before the processing begins. We may use carefully controlled digital tools to support administration or drafting, but remain responsible for decisions and do not intentionally place confidential or special-category information into tools that are not approved for that purpose.
Changes and contact
We may update this notice when our services, suppliers or legal obligations change. The date at the top shows the latest revision. Material changes will be highlighted where appropriate.
For questions, rights requests or complaints, contact:
Divergent Training Ltd trading as Divergent Thinking
71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Email: nat@divergentthinking.uk