Privacy Notice | The People Choreographer

How The People Choreographer® handles your personal data

Last updated: May 2026 | Version 1.0

The People Choreographer® is committed to protecting your privacy and handling your personal data with care, transparency and respect. This notice explains what information we collect, how we use it, who we share it with, and the rights you have over your data.

People Choreographer® is the trading name of Rachel Atkinson, an independent HR and people consultant operating as a limited company. Rachel Atkinson is the data controller responsible for your personal data and is registered with the Information Commissioner’s Office (ICO).

1. Who we are and how to contact us

Data Controller: Rachel Atkinson (trading as The People Choreographer® Ltd)

Email: rachel@peoplechoreographer.co.uk

Based in:
The People Choreographer
Patch Places
1st Floor, Bobby’s
2-12 Commercial Road
Bournemouth
BH2 5LP

ICO Registration: ZA821576

If you have any questions about this notice, want to exercise your rights, or wish to make a complaint about how we handle your data, please contact us at the email address above.

2. Who this notice applies to

This notice applies to:

Clients and client contacts, individuals and organisations who engage People Choreographer® for HR consultancy, recruitment, training, or related services, and the staff or representatives we work with on those engagements.
Job candidates, individuals who apply for roles where People Choreographer® is managing the recruitment process on behalf of a client.
Employees and workers of client organisations, individuals whose personal data is shared with us in the course of HR casework, employment law advisory, job evaluation, or other people-related projects we deliver for clients.
Website visitors and enquirers, anyone who visits our website, contacts us through it, or otherwise enquires about our services.

3. The personal data we collect

The categories of personal data we process depend on your relationship with us. The table below summarises the most common types of data we hold.

Clients and client contacts

Name, job title, employer, and business contact details
Correspondence with us (emails, messages, meeting notes)
Information needed to deliver the services agreed (which may include workforce information, organisational structures, policies and other business information)
Billing and payment information

Job candidates

Name, contact details, CV/application content, and right to work information
Application history, interview notes, assessment results, and references
Equal opportunities monitoring data (where collected, this is processed separately and on an anonymised basis where possible)

Employees and workers of client organisations

Where a client shares personal data with us in the course of an HR matter, we may process data such as:

Name, job title, employment history, and contractual information
Performance, conduct, grievance, disciplinary, sickness or capability information relevant to the matter
Health, wellbeing or occupational health information where relevant to the matter
Other special category or sensitive data where strictly necessary (for example, in equality, harassment or safeguarding-related casework)

In these cases, the client organisation is typically the data controller and The People Choreographer® acts as a data processor on their behalf, under the terms of our engagement. Where we provide standalone advice or templates not tied to a specific individual, we may act as a controller in our own right.

Website visitors and enquirers

Name, email address, and the content of any enquiry you submit
Technical information collected via the website (such as IP address and browser type) and cookies, where used, in line with our Cookie Policy

4. Why we use your data and the legal basis

We only process personal data where we have a lawful basis to do so. The most common bases we rely on are:

Contract, to enter into and perform a services agreement with you or your organisation.
Legitimate interests, to run, promote and improve our consultancy practice, manage client relationships, respond to enquiries, and keep proper business records, in a way that does not override your rights.
Legal obligation, to meet obligations under tax, accounting, employment, and other applicable laws.
Consent, for example, to send you our newsletter via Transpond, where required. You can withdraw consent at any time by unsubscribing or contacting us.
Special category data, where we process health, equality or other special category data in the course of HR casework, we rely on additional bases under Article 9 UK GDPR, typically employment, social security or social protection law (Schedule 1, Part 1 of the Data Protection Act 2018).

5. How we use AI tools in our work

Transparency on this point matters to us. We sometimes use generative AI tools (currently Claude, developed by Anthropic) as a drafting and thinking aid, for example, to help refine wording in policies, sense-check the structure of long documents, or speed up routine correspondence. AI is never used as a substitute for our professional judgement, and any output is reviewed and adapted before it reaches you.

The safeguards we apply when using AI tools are:

The setting that allows the AI provider to use our conversations to train their models is switched off. This means data shared in our chats is retained for 30 days only and is not used to improve the AI.
We anonymise client information before entering it into any AI tool- using initials, generic terms, role titles, or generic descriptors rather than names, organisation details, or identifying facts.
We do not enter sensitive personal data, such as health information, settlement details, or safeguarding-related material, into AI tools. Work of that nature is drafted directly.
Our AI provider encrypts data in transit and at rest, and states that it does not sell user data to third parties. Conversations may, in limited circumstances, be reviewed by the provider if flagged for safety reasons under their Usage Policy.

If you would prefer that we do not use AI tools in connection with your work, please let us know and we will note that on your file.

6. Who we share your data with

We do not sell your personal data. We share it only where necessary, and only with parties who have appropriate safeguards in place. Categories of recipient include:

Our clients, where we are processing data on their behalf as part of an engagement (for example, sharing candidate information during a recruitment project).
Service providers, trusted third parties who help us run our business, including:

- Microsoft 365 (email, document storage, and collaboration)
- Capsule (our CRM, which holds contact records and feeds into Transpond)
- Transpond (email marketing platform used for newsletters, where you have subscribed)
- FreeAgent (our accounting software, used for invoicing and bookkeeping)
- Anthropic (provider of the Claude AI tool described in section 5)
- Our website host and any analytics provider

Professional advisers, such as our accountant or legal advisers, where needed.
Regulators and authorities, where required by law (for example, HMRC, the ICO, or in response to a lawful request).

All providers are bound by contractual obligations to protect your data and to use it only for the purposes we have agreed.

7. International transfers

Some of the providers listed above (including Microsoft and Anthropic) are based outside the UK or process data internationally. Capsule, Transpond and FreeAgent are UK-based providers, but may also process data outside the UK depending on their hosting arrangements. Where personal data is transferred outside the UK, we rely on appropriate safeguards recognised under UK data protection law, such as UK adequacy regulations, the UK International Data Transfer Agreement, or Standard Contractual Clauses with the UK Addendum, to ensure your data remains protected.

8. How long we keep your data

We keep personal data only for as long as necessary for the purposes for which it was collected, including any legal, accounting or contractual requirements. In general:

Client engagement records, kept for the duration of our engagement and for up to 6 years after it ends, in line with HMRC and limitation period requirements.
Recruitment records (unsuccessful candidates), kept for up to 12 months after the recruitment process closes, unless you ask us to delete them sooner or to retain them for future opportunities.
HR casework records, retained in line with the client organisation’s instructions and our engagement terms, and then securely deleted or returned.
Marketing data, kept for as long as you remain subscribed, and deleted within a reasonable period after you unsubscribe.
Website enquiries, kept for up to 2 years from the date of enquiry, unless they lead to an engagement.

9. How we keep your data secure

We take the security of your personal data seriously. Our measures include encrypted storage and email, password-protected devices, multi-factor authentication where available, and access controls limiting who can see what. We review our suppliers and tools regularly to ensure they continue to meet appropriate standards.

10. Your rights

Under UK data protection law, you have the right to:

Be informed about how your personal data is used (this notice)
Access a copy of the personal data we hold about you
Request correction of inaccurate or incomplete data
Request deletion of your data in certain circumstances
Restrict or object to certain types of processing
Data portability, where applicable
Withdraw consent at any time, where consent is the basis we rely on
Lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113

To exercise any of these rights, please email rachel@peoplechoreographer.co.uk. We will respond within one month.

11. Changes to this notice

We may update this notice from time to time to reflect changes in our practices, the tools we use, or the law. The version date at the top of this notice shows when it was last updated. Significant changes will be brought to your attention where we hold contact details for you.