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MOMENTUM PRIVACY

Your development deserves a clear privacy boundary.

This notice explains what personal information Momentum uses, why we use it, who may receive it and the choices and rights you have. It also explains the additional boundary that applies when an organisation funds someone’s participation.

Effective: 12 September 2026 · Version 1.0

The short version

We use information to operate Momentum, assess and support development, administer participation and improve the service. An employer or sponsoring organisation does not automatically receive your private assessment answers, reflections, Guide conversations or developmental record.

On this pageAt a glanceWhat we collectWhy we use itOrganisation-funded participationWho we share information withHow long we keep informationYour rightsSecurity and international processingContact and complaints

At a glance

Momentum™ is a UK-based people and business performance system. For privacy questions, requests or concerns, contact info@buildmomentum.uk.

Important governance point: funding participation does not mean owning a participant’s development record. Where an organisation sponsors a place, Momentum separates private individual developmental information from information that has been specifically agreed as organisation-permitted reporting.

This notice applies to Momentum websites and digital services, applications, assessments, programme participation, Guide interactions, reports, organisational cohorts and related communications.

What we collect

Depending on how you interact with Momentum, we may collect:

  • identity and contact information such as your name, email address and phone number;
  • working, business or organisational context you provide in an application or onboarding process;
  • assessment responses, scores, reflections, development priorities, Meaningful Actions, progress evidence and programme feedback;
  • information needed to administer invitations, accounts, participation, sponsorship, payments and support;
  • communications with Momentum and information you choose to provide to a Guide;
  • technical information needed to operate and secure the service, such as source page, device/browser information, timestamps and service logs;
  • marketing preferences and consent choices.

Information that may be more sensitive

Because Momentum considers Physical, Mental and Relationship Performance, people may sometimes choose to provide information concerning health or other sensitive circumstances. We do not ask participants to provide more sensitive information than is reasonably necessary for the developmental purpose, and we apply additional care to access and sharing.

Why we use it

We use personal information where it is necessary to take steps at your request, provide and administer Momentum services, meet legal obligations, pursue legitimate interests in operating and improving a safe and effective service, or where you have given consent for a particular purpose such as optional marketing.

Typical purposes include reviewing applications, establishing a performance baseline, generating participant and Guide outputs, supporting Guide-led development, operating the 90-day journey, administering accounts and commercial relationships, preventing misuse, maintaining service security, communicating about participation and improving Momentum.

Where a different lawful basis or an additional condition is required for more sensitive information, Momentum must identify and document that basis before relying on the information for that purpose.

AI-assisted interpretation

Momentum may use governed AI-assisted processes to help organise, interpret or draft insights from assessment and developmental evidence. These tools support the Momentum process; they do not replace the human authority reserved for decisions such as application progression, Guide validation or commercial invitation. We do not intend to make solely automated decisions that have legal or similarly significant effects on participants.

Organisation-funded participation

If an employer or another organisation funds your place, Momentum may need to process information about the sponsorship relationship, cohort, eligibility, participation status and agreed programme outcomes.

Your private developmental information is not automatically employer-visible. This includes individual assessment answers, private reflections, Guide conversations and the detailed developmental record unless a separate, clear and appropriate basis for sharing has been established.

Before organisational reporting begins, Momentum and the sponsoring organisation should agree what information is organisation-permitted. This may include appropriate cohort-level participation, completion, aggregated movement, non-identifying themes or other specifically governed measures. We aim to avoid reporting that unnecessarily identifies an individual.

If a sponsorship ends, that does not by itself transfer ownership of your Momentum history to the sponsor.

Who we share information with

We may use trusted service providers to operate Momentum, including providers for secure hosting and databases, authentication, email delivery, payments, website hosting and other technology needed to deliver the service. They may process information on our behalf under appropriate contractual and security arrangements.

We may also disclose information where required by law, to protect legal rights or service security, or where you have asked or authorised us to do so. Organisation-funded reporting follows the sponsorship boundary described above.

We do not sell participants’ personal information to advertisers.

How long we keep information

We keep information only for as long as it is reasonably needed for the purpose for which it was collected, to maintain appropriate programme and longitudinal records, to meet legal/accounting obligations, to resolve disputes or to protect legitimate legal interests. Different categories may therefore have different retention periods.

We review retention as the Momentum service develops and securely delete or anonymise information when it is no longer required. Where a participant continues across different funding arrangements, an appropriate longitudinal development history may continue with the individual rather than being treated as the property of a former sponsor.

Your rights

Depending on the circumstances and the lawful basis being used, UK data protection law may give you rights including:

Access to personal information we hold about you.
Correction of inaccurate or incomplete information.
Erasure in circumstances where the right applies.
Restriction of processing in applicable circumstances.
Data portability where the legal conditions are met.
Objection to certain processing, including direct marketing.

You can object to direct marketing at any time. Where we rely on consent, you may withdraw that consent without affecting processing already carried out lawfully before withdrawal.

To exercise a right, contact info@buildmomentum.uk. We may need to verify your identity before acting on a request.

Security and international processing

Momentum uses technical and organisational controls intended to protect information against unauthorised access, loss, alteration or disclosure. Access to developmental information is governed according to role and purpose.

Some technology providers may process information outside the UK. Where this happens, Momentum will use an appropriate lawful transfer mechanism or other safeguard required by UK data protection law and will keep those arrangements under review.

Cookies and similar technologies

Momentum may use technologies that are necessary to operate authentication, security and core website functions. If we introduce non-essential analytics, advertising or similar cookies, we will provide the required information and choices before using them where consent is required.

Contact and complaints

For privacy questions, to exercise a data protection right or to raise a concern, email info@buildmomentum.uk.

You also have the right to complain to the UK Information Commissioner’s Office (ICO). We would welcome the opportunity to address your concern directly first, but you do not have to contact us before approaching the ICO.

This notice will be reviewed as Momentum’s services, suppliers and data uses develop. Material changes will be brought to people’s attention where required.

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