Privacy Policy

Our contact details

Name: Organisational Reflections Ltd. trading as i-comment360 

Address: Kirklands House, Saline, Fife, KY12 9TS

Phone Number: 01838 851632  



The type of personal information we collect

We currently collect and process the following information:

  • Personal identifiers, contacts and characteristics (for example, name, e-mail address and contact details).
  • Responses provided by participants and their colleagues to online questionnaires.
  • The personality “type” and position on the Persona wheel of an individual resulting from their responses to the questionnaire.

When a participant completes an online questionnaire, they provide responses which are used to compile the resulting reports.  The majority of responses collected are presented anonymously in reports. 


How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following reasons:

  • Purchase and completion of online questionnaires and reports, and coaching
  • Participants undertaking a 360 feedback exercise, colleagues providing 360 feedback, participants filling in a survey or personality profile, or undertaking coaching or team sessions.

We also receive personal information indirectly, from the following sources in the following scenarios:

  • Training companies, coaches, organisations or team managers provide the names and e-mail address of their employees or team members for the purposes of undertaking a 360 feedback exercise, survey or completing personality profiles.
  • 360 feedback Participants nominate colleagues to provide feedback. They input the names and e-mail addresses of those colleagues into the system for the purposes of sending a link to the colleague to complete the feedback.

We use the information that you have given us in order to:

  • send links to participants (and their colleagues for 360 feedback) to complete online questionnaires,
  • to resolve any queries such as providing technical assistance or check the validity of information entered into the system (e.g. correct e-mail address typos),
  • to provide copies of the resulting reports, and/or
  • to provide any coaching or teambuilding sessions purchased.

We may share this information with the training company, organisation, coach or individual who has ordered the online questionnaire and report.  Where noted that feedback is anonymous, names are removed from feedback, however it is presented by analysis group so if there is only one person in a group e.g. a line manager for 360 feedback, the feedback may be identifiable. 

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

(a) Your consent. By completing the online questionnaire, you are giving your consent for the scores and feedback you provide to be included in the resulting report.  You are able to remove your consent at any time. You can do this by contacting

(b) We have a contractual obligation.  The order / purchase of 360 feedback, surveys, personality profiles or coaching is the basis of this contract.


How we store your personal information

Your information is securely stored.   

We keep names, e-mail addresses and responses to online questionnaires for two years after the delivery of the service.  Where online questionnaires and reports are provided to organisations who continue to use our services, data is kept for 2 years after the end of the contract with that organisation.  Data is kept for two years to allow previous scores to be included in follow up feedback exercises or team reports to be run for changes in team members. 

This information is stored electronically in the feedback and personality systems. 

We will then dispose your information by:

  • deleting names and e-mail addresses from the system,
  • anonymising scores provided in surveys and 360 feedback to allow the creation of benchmarks,
  • anonymising responses to personality questionnaires so that anonymous data can be used for validation purposes.


Your data protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at if you wish to make a request.


How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane

Helpline number: 0303 123 1113

ICO website: