Privacy Notice
How we look after your information
This notice covers both the !GNITE Programme and the Spark Initiatives executive performance practice.
Who we are
Spark Initiatives Ltd is the data controller for personal data collected in connection with both the !GNITE Programme and the Spark Initiatives performance practice. You can contact us at ignite@
!GNITE Programme: what data we collect
For participants (aged 14 to 25) and parents or guardians, we collect:
- Your name, age, and date of birth
- Your contact details (email address, phone number)
- Your educational institution and year group
- Your parent or guardian's contact details (if you are under 18)
- Information about your attendance at !GNITE workshops and events
- Feedback you provide about the programme
- Outcome information, for example whether you went on to university, an apprenticeship, or employment (shared voluntarily)
- Photographs or video footage if you have given consent for this
!GNITE Programme: why we collect it and the legal basis
| Why we use your data | Our legal basis |
|---|---|
| To manage your participation in the programme | Performance of our agreement with you |
| To contact you about upcoming events and workshops | Your consent |
| To measure the impact of the programme | Our legitimate interests |
| To contact your parent/guardian (if under 18) | Legal obligation (safeguarding) |
| To share photos/videos for promotional purposes | Your explicit consent |
We keep !GNITE participation data for as long as you are an active participant, and for up to three years after your participation ends, for impact measurement purposes. Safeguarding-related records are retained for a minimum of 10 years.
Spark Initiatives performance practice: what data we collect
Depending on which service you use, this may include: contact and enquiry details; diagnostic and coaching session data; and, where you consent to the full diagnostic, health-adjacent data such as sleep, recovery, and stress physiology metrics. This last category is special category data under UK GDPR Article 9 and is only collected with your explicit, separate consent, never as a condition of using our other services.
Spark Initiatives performance practice: legal basis
| Why we use your data | Our legal basis |
|---|---|
| Contact and enquiry data | Legitimate interest in responding to you |
| Coaching and diagnostic data | Performance of our contract with you |
| Special category health-adjacent data | Your explicit consent, withdrawable at any time without affecting other services |
We retain practice engagement records, including diagnostic and coaching data, for 8 years after the formal engagement relationship ends.
Who we share your data with
We do not sell your personal data. We may share it with our volunteers (Catalysts) and Torchbearers for !GNITE delivery purposes, our practitioners for Spark Initiatives practice delivery, our technology providers under strict data processing agreements, and statutory agencies where required by law or safeguarding duties.
Your rights
You have the right to: see the data we hold about you (a Subject Access Request); ask us to correct inaccurate data; ask us to delete your data (in some circumstances); object to how we use your data; and withdraw your consent at any time where we are relying on consent.
To exercise any of these rights, please contact us at the relevant email address above.
Complaints
If you are unhappy with how we handle your data, you have the right to complain to the Information Commissioner's Office (ICO) at www.ico.org.uk.
Photographs on this site
Some photographs on this site are AI-generated illustrations. They do not show real clients, participants or other individuals.
Changes to this notice
We may update this notice from time to time. The current version is always available on our website.