Data Protection & Privacy Policy

At Zomi Communications Limited (incorporating The Gravitas Programme®, Leading with Gravitas® and Antoinette Dale Henderson brands), we recognise that integrating Corporate Social Responsibility (CSR), Environmental, Social and Governance (ESG) and Sustainability principles into our business operations is essential to building a sustainable and responsible company.

Purpose

Zomi Communications Limited is committed to protecting the privacy and personal data of our clients, participants, associates, contractors, and website visitors. This policy outlines how we collect, process, store, and safeguard personal data in compliance with the UK Data Protection Act 2018 and GDPR principles.

Scope

This policy applies to:

  • All personal data collected, processed, or stored by Zomi Communications Limited, including through The Gravitas Programme and Antoinette Dale Henderson brands
  • All employees, contractors, associates, and service providers handling personal data

Principles of Data Protection

We process personal data lawfully, fairly, and transparently. Our approach is based on the following principles:

  1. Purpose Limitation: Personal data is collected only for legitimate purposes and is used only as described to the data subject.
  2. Data Minimisation: We collect only the minimum personal data necessary for service delivery.
  3. Accuracy: Personal data is accurate, complete, and kept up-to-date.
  4. Storage Limitation: Personal data is retained only for as long as necessary to fulfil its purpose.
  5. Integrity & Confidentiality: Data is protected against unauthorised access, loss, or disclosure.

Collection of Personal Data

We may collect:

  • Contact information: Name, email, phone number
  • Professional information: Job role, organisation, or sector
  • Programme participation data: Feedback forms, survey responses, or attendance records
  • Website usage data: Non-identifying information collected via cookies or analytics

All personal data is collected fairly and with consent, with clear explanation of purpose and usage.

Use of Personal Data

Personal data is used to:

  • Deliver training, coaching, and consulting services
  • Communicate programme updates, scheduling, and follow-ups
  • Understand client and participant needs to improve services
  • Comply with legal, regulatory, and contractual obligations

We do not sell, rent, or otherwise disclose personal information to third parties except where necessary to deliver services, or as required by law.

Rights of Data Subjects

Individuals have the right to:

  • Access their personal data held by us
  • Correct or update inaccurate personal data
  • Request deletion or restriction of processing where appropriate
  • Object to processing for marketing purposes
  • Withdraw consent at any time

Requests can be submitted by contacting antoinette@gravitasprogramme.com.

Data Storage & Retention

  • Data is stored securely on password-protected systems and cloud services with commercial-grade safeguards.
  • Personal data is retained only as long as necessary for business or legal purposes and securely deleted thereafter.

Third-Party Access & Transfers

  • Third-party service providers may process data on our behalf (e.g., email, cloud storage, analytics).
  • Providers are contractually required to maintain data confidentiality and comply with data protection regulations.
  • We do not transfer personal data outside the UK/EU without ensuring equivalent data protection standards.

Breach Management

In the event of a data breach, Zomi Communications Limited will:

  • Contain and investigate the breach promptly
  • Notify affected individuals and relevant authorities where required
  • Take corrective action to prevent recurrence

Cookies

Our website uses cookies to analyse site traffic and improve user experience. Users may control cookie preferences via browser settings. No personal data is collected through cookies without consent.

Commitment

Zomi Communications Limited is committed to protecting personal data, respecting privacy, and ensuring transparency in all data processing activities. All associates, contractors, and staff are required to comply with this policy.

Approved by:
Antoinette Dale Henderson
Managing Director, Zomi Communications Limited

This policy is effective as of January 21, 2025.

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