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Privacy & Cookie Policy

The OCM Group Privacy Policy

The OCM is a professional coaching and mentoring firm based in the UK. This privacy policy explains how we use any personal information we collect about you when you are a client of ours, use our website, or opt-in to receive useful knowledge materials, articles and newsletter

Your privacy is important to The OCM Group. This privacy policy provides information about the personal information that The OCM Group collects and the ways in which The OCM Group uses that personal information. It also outlines how we protect your data and your rights to access, correct or delete it.

Privacy and The OCM Group website

Personal information collection

We collect the e-mail addresses and certain personal information of those who communicate with us via e-mail or register with us to receive useful knowledge materials, articles and newsletters. We also collect certain information regarding which pages users access or visit, and information volunteered by the users (such as any surveys or web forms that may appear on our site).

We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you.  This helps us to update, expand and analyse our records, identify new customers, and provide products and services that may be of interest to you.  If you provide us with personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

Privacy Policy

1. Introduction

The OCM ("we", "our", "us") is committed to protecting the privacy of visitors to our website. This Privacy Policy explains how we collect, use, store, and safeguard your personal data when you interact with our website and its services. It also explains how we use Google Analytics 4 (GA4) to analyse website activity.

2. Data We Collect

2.1 Data Collected Automatically (via GA4)

When you visit our website, we use Google Analytics 4, a web analytics service provided by Google LLC, to help us understand how visitors use our website. GA4 collects the following types of data:

  • Online identifiers and cookies or cookieless pings.
  • Device and browsing data such as browser type, device model, operating system version, and screen resolution.
  • Approximate location data, including city, country, and region, based on anonymised IP processing performed on EU servers.

GA4 does not log or store IP addresses by default, and sensitive data collected within the EU is dropped before processing.

2.2 Data You Provide Voluntarily

If you contact us via forms, email, or other methods, we may collect the personal information you choose to provide (e.g., your name, email address, and message content).

3. How We Use Your Data

We process personal data for the following purposes:

  • To analyse website traffic and understand user behaviour using GA4.
  • To maintain and improve our website and services.
  • To respond to enquiries and provide support.
  • To comply with legal obligations.

4. Legal Basis for Processing

For visitors from the UK and EU, we rely on:

  • Consent for analytics cookies and tracking technologies, as required under GDPR and ePrivacy rules.
  • Legitimate interest for essential site operations not involving analytics tracking.

You may withdraw consent at any time using our cookie settings tool.

5. Cookies & Tracking Technologies

We use cookies and similar technologies to operate our site and, when permitted by you, to measure performance and usage. This website does not store any information that would, on its own, allow us to identify individual users of this service without their permission. Any cookies that may be used by this website are used solely on a ‘per session’ basis or to maintain user preferences. Cookies are not shared with any third parties.

Your consent banner will provide:

  • An equal choice to accept or reject analytics cookies.
  • Options to change your preferences later.

6. International Data Transfers

When GA4 processes data, it may involve transfers outside the UK/EU. Although GA4 has strengthened privacy safeguards—such as EU‑based IP anonymization—Google may still process some data on servers in the United States or other countries.

To ensure lawful transfer, Google relies on:

  • Standard Contractual Clauses (SCCs),
  • Additional safeguards described in Google’s Measurement Controller‑Controller Data Protection Terms.

We recommend reviewing Google’s Privacy & Terms for additional information.

7. Data Retention

Data collected through GA4 is retained for either 2 or 14 months, depending on configuration. We use the shortest retention period necessary for analytics purposes.

Information you provide directly (e.g., enquiries) will be retained only for as long as reasonably necessary.

8. Your Rights

Depending on your location, you may have the right to:

  • Access your personal data.
  • Request correction or deletion.
  • Withdraw consent for analytics at any time.
  • Object to or restrict processing.
  • Lodge a complaint with the Information Commissioner’s Office (ICO).

We will respond to all rights requests in accordance with applicable laws.

9. How We Protect Your Data

We implement appropriate technical and organizational measures, including data minimization, secure storage, and restricted access. GA4 also employs privacy‑focused features such as reduced data retention, no IP logging, and regional data controls.

10. Third‑Party Processors

Your data may be processed by:

  • Google LLC, for analytics services.

    All such processors are required to implement data protection measures consistent with GDPR requirements.

11. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legal requirements or our data practices. Any updates will be posted on this page.

12. Contact Us

If you have questions about this Privacy Policy or how we handle your personal data, please contact us at:

The OCM

Email: [email protected]

Address: The OCM, Unit 1, Bennetts Farm, West Woodhay, Berkshire , RG20 0BL, United Kingdom.

 

Privacy as a client of The OCM

Why we collect information

When you become a client of The OCM Group we will collect some personal data either in order to deliver our services to you, typically a coaching contract, qualification or training programme or for the purposes of our legitimate interest in performing our business ethically and in line with our terms and conditions and Privacy Policy.

This includes enabling The OCM Group Staff and contracted Associates to contact our clients to schedule coaching sessions and/or meetings in accordance with our contractual commitments. As a client of The OCM Group we may also have legitimate interest to contact you for the purposes of communicating useful ‘knowledge’ materials, articles and newsletters.

What information we collect

In order to fulfil our contractual obligations we may collect the following information:

  • Client name
  • Company title and company name and company address
  • Contact telephone numbers
  • E-mail and/or Skype address(es)
  • Basic notes of actions and key points arising from our coaching sessions when working together
  • Any information relating to your qualification or training programme including all Assessment material that we have a legal obligation to keep for the purposes of fulfilling our Quality Assurance responsibilities to our accreditation partner the European Mentoring and Coaching Council (EMCC)

Consent

For coaching clients

The coach will seek the client consent during the first coaching session.

For qualification or training clients

We will seek consent when you apply to enrol on one of our qualification or training programmes. The consent form will be part of your online application.

The systems we use to process your data

In order to fulfil our contractual obligations we may use one or several of the following proprietary or third party systems:

  • Sugar CRM (3rd party, Sugar CRM, Inc, USA)
  • Active Camapign (3rd party ActiveCampaign Software, Inc, USA)
  • The Learning Pathway (3rd party, People Alchemy Ltd, UK)
  • Excelerated (3rd party, Cambria Consulting, Inc, USA)
  • Stripe (3rd party Stripe, Inc, USA)
  • GetFeedback, (3rd Party, GetFeedback, Inc, USA)

Please see our Third Party and International Transfer statements below.

Your rights

The OCM Group use Sugar CRM as our main platform to store and process the data we hold on you, unless you are part of a qualification or training programme where information is held on the Learning Pathway. If you are receiving coaching information is held in Excelerated.

Access to your information and correction of data

Whatever your contact with us, you have the right to request a copy of the information that we hold about you. If you would like to access the data we hold on you, please email or write to us at the address located at the end of this policy. We will reply in full within 1 month of receiving your request, unless the information is particularly complex. If we need more time we will let you know. Please leave contact details on any correspondence sent to us.

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. We will delete or update your information within 48 hrs.

Withdrawing consent and objections to processing

You have the right to withdraw consent for us to have your data and the right to object to it being processed in any particular way. If you wish to do this, please email or phone us using the contact details given below. Please note that in accordance with the law around data protection, we aim to anonymize data as soon as possible. If we have already anonymized your responses, it may not be possible for us to give you a copy of the data you have submitted, or to correct, remove or withdraw it.

Your right to lodge a complaint

If you would like to complain about how your data has been treated by us please contact our Data Protection Officer at the address below. To take your complain further, contact our Chief Executive, Ed Parsloe. Under GDPR, you also have a right to lodge a complaint with the supervisory authority in your state of residence, place of work or where the alleged breach of GDPR occurred. In the UK this is the ICO.

Keeping your data safe

The OCM Group takes information security risks very seriously and takes all reasonable technical and organisational precautions to prevent the loss, misuse and / or alteration of your personal information.

In addition, we hold a Cyber Essential Plus Certificate which will further enshrine best practice principles into all our organisational processes. The OCM Group securely store all the personal information you provide and, if not already in existence, we will create a number of company policies related to this. These include policies on: 

  • BYOD
  • Monitoring for breaches and breach protocols
  • Employee access and password changes
  • Leavers and starters policies
  • Work station security
  • Wireless communication use
  • VPN use
  • Software installation
  • Server Malware Protection
  • Router Security
  • Remote access
  • Mobile Employee Endpoint Responsibility
  • Information sensitivity
  • Bluetooth security
  • Email & IM use
  • Acceptable use
  • Acceptable encryption
  • Anti-virus

Policies are and will be revised at a minimum annually with discussions on requirements to change built into our weekly Directors meeting on a monthly basis All staff are or will be given training on cyber security risks and policies annually or when policies change.

Retention of your data

We will keep your data no longer than is necessary within UK Law. We conduct regular audits of the data.

International data transfers

The GDPR imposes restrictions on the transfer of personal data outside the EEA, to third countries or international organisations. We follow these regulations, meaning that without your explicit consent your personal data will only be transferred outside of the EEA under the following circumstances:

• Where the Commission has decided that a third country, a territory or one or more specific sectors in the third country, or an international organisation ensures an adequate level of protection.

• Where the organization receiving the personal data has provided adequate safeguards e.g. certification under an approved certification mechanism.

Third parties

With the exceptions below, The OCM Group does not share, sell, rent, or trade personally identifiable information with third parties for their promotional purposes. However, we may need to share your information with our agents or sub-contractors or third parties to deliver our contractual obligations. For example, we will share personal data to associates coaches, mentors, supervisors or facilitators when appropriate. When this is the case, for these purposes, the agent or sub-contractor or third parties in question will be obligated to use that personal information in accordance with the terms of this privacy statement.

If the ownership of our business changes, for example we are bought by another company or merged with one, we would need to transfer your data to this new owner. We would ensure that your data is transferred to them securely and in accordance with our privacy policy.

In addition to the disclosures reasonably necessary for the purposes identified above, The OCM Group may disclose your personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights.

Changes to our privacy policy

We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated February 2026.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you by email to [email protected] or phone us on +44 (0) 1869 338989.

The OCM Group Ltd, Unit 1, Bennetts Farm, West Woodhay, RG20 0BL

Please leave contact details on any correspondence and we will contact you to let you know it has been received.