Last updated 3 November 2026

Who we are

Sway Scientific Limited ("Sway", "we", "us") is an organisational psychology and leadership advisory firm, registered in England and Wales (company number 15706837), with its registered office at c/o Veritons Ltd, Innovation Centre Medway, Maidstone Road, Chatham, Kent ME5 9FD. We are registered with the Information Commissioner's Office under reference ZC289098.

We work in two ways: Sway Leadership Advisory (coaching, and advice on organisation design, development and people strategy) and Sway Voicebox™, our confidential AI-guided conversations that help organisations hear from their people.

Who this notice covers

This notice explains how we handle personal information about:

- people who take part in a Voicebox conversation (see the Voicebox participants section below)

- people we coach, and people who take part in 360 reviews, psychometric assessments or workshops

- our clients' contacts, prospective clients and partners

- people who contact us through our website

Our staff and contractors have a separate staff privacy notice.

When we work with an organisation, Sway and that organisation are each responsible, as separate controllers, for the personal information they handle. We decide how our conversations, assessments and analysis are designed and carried out. The organisation decides to commission the work, who is invited to take part, and how it uses the findings we give it.

What we collect and why

Voicebox participants

What we collect: transcripts of what you say or type, and the optional details set out in the Voicebox participants section below.

Why, and our lawful basis: to understand how people experience work and give the organisation group-level findings. Legitimate interests.

How long we keep it: transcripts are deleted 12 months after the final report, or sooner if agreed with the organisation.

Coaching clients

What we collect: your contact details, coaching notes, and session recordings only if you agree.

Why, and our lawful basis: to deliver coaching under our agreement with you and your sponsor. Contract and legitimate interests.

How long we keep it: notes are kept for 2 years after coaching ends; recordings are deleted once notes are written.

Client contacts and prospects

What we collect: name, job title, work contact details and correspondence.

Why, and our lawful basis: to deliver and manage our work and discuss future work. Contract and legitimate interests.

How long we keep it: 6 years after the engagement ends, for contract and tax records.

People who contact us

What we collect: your name, email address and anything you include when you email info@swayatwork.co.

Why, and our lawful basis: to reply to you. Legitimate interests.

How long we keep it: up to 2 years after our last contact, unless it leads to work together.

Group-level reports and findings, which contain no names or transcripts, are kept for the life of the client relationship plus 6 years. We never sell personal information, and we do not use it to make decisions about anyone by automated means. Our website does not use analytics, tracking or marketing cookies, and we do not send marketing emails.

Where your information comes from, and whether you have to give it. Most of what we hold comes from you. If your organisation arranges coaching or a 360 review, it may give us your name and work contact details to set this up. For Voicebox, your organisation sends the invitation itself and we receive no list of names. You are not required by law to give us any information: you can take part in Voicebox without giving us any personal information at all, and for coaching we need your contact details to deliver it under our agreement.

Voicebox participants

Your organisation has asked Sway to hold confidential conversations with its people about what it is like to work there. You talk to an AI interviewer, by voice or by typing. Taking part is voluntary and you can stop at any time.

What we keep. A written record of your conversation. No audio is stored, and your voice is never analysed. We do not ask for your name. If you choose to ask for follow-up, we also keep your email address.

Confidential, not anonymous. Your conversation is confidential: only Sway's team works with it, and your organisation never sees it. Your organisation receives findings reported only in aggregate. We check any quotes for details that could let people recognise you, and remove or paraphrase them to protect your identity. We cannot promise anonymity, because details such as your role, team or circumstances may let people who know the workforce recognise you, so please share only what you are comfortable sharing.

Follow-up. If you ask for follow-up, your organisation's People & Culture team receives your email address only, not your conversation, so please raise anything you need them to act on with them directly.

Serious concerns. If you raise your health or another sensitive matter, the interviewer will point you to support rather than explore it. If you tell us about a serious risk of harm, including imminent harm to yourself or others, we have a duty of care to act, following a process agreed with your organisation. Because we do not ask who you are, we may not be able to identify you or pass on enough information for anyone to help. If you or someone else is in immediate danger, please contact the emergency services (999 in the UK, 911 in the US).

Why, and for how long. We rely on legitimate interests, ours and your organisation's, in understanding and improving the workplace. Transcripts are deleted 12 months after the final report.

Deleting your conversation. Email privacy@swayatwork.co with the date and time you took part, and we will delete it. Once findings have been combined into a report, your contribution cannot be separated out.

Coaching and psychometric participants

Coaching starts with a written agreement between you, your coach and your sponsor, which sets out what stays confidential, what your sponsor receives, and the limits of confidentiality. We only record a session if you agree each time, and we delete the recording once notes are written. Psychometric reports go to you first, and to your sponsor only if you agree.

Who we share it with

We share personal information only with:

- Service providers that help us run our work, each under a data processing agreement that requires them to keep it secure and use it only on our instructions. For Voicebox these are Vercel (hosting), Neon (database), ElevenLabs (voice conversations), Anthropic (chat conversations and analysis support), OpenAI (backup analysis if Anthropic is unavailable) and Resend (service emails). For the rest of our work we use Google Workspace, Slack and Asana. Our AI providers' business terms prohibit training their models on our data.

- The organisation that commissioned the work, as described in the sections above.

- Professional advisers, insurers or authorities, where needed to protect our legal position or where the law requires it.

International transfers. Sway is based in the UK, and most of our providers store information in the United States. These transfers are protected by the UK–US Data Bridge where the provider is certified, and otherwise by the standard contractual clauses or UK addendum in the provider's data processing agreement. You can ask for a copy of these safeguards by emailing privacy@swayatwork.co.

How we protect it, and how we use AI

We protect information with multi-factor authentication, access limited to the people working on each engagement, encryption in transit and at rest, and a written incident response plan. If a personal data breach puts people at risk, we tell the ICO within 72 hours and inform the people affected where the risk to them is high.

We use AI to hold Voicebox conversations and to support our analysis. Every output is reviewed by a person before it reaches a client, and AI is never used to score, rate or make decisions about individuals.

Your rights

You can ask us for a copy of the information we hold about you, and ask us to correct it, delete it, restrict how we use it, or transfer it. Where we rely on your consent, such as for recording a coaching session, you can withdraw it at any time by telling your coach or emailing privacy@swayatwork.co. We will respond within one month. Some rights are limited where we must keep information by law, or where your information has already been combined into a report.

Your right to object. Most of what we do relies on legitimate interests, and you have the right to object to that at any time. Email privacy@swayatwork.co and we will stop, unless we have compelling grounds to continue that override your interests.

If you are outside the UK. We give the same rights to everyone who takes part in our work, wherever they are based, including in the United States.

Contact us and complaints

For any question about this notice, or to use your rights, contact our Security & Privacy Lead, Olivia Griffiths, at privacy@swayatwork.co, or write to us at the address above. We acknowledge complaints within 30 days.

If you are unhappy with how we have handled your information, please tell us first so we can put it right. You can also complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113.

We may update this notice, and the date at the top shows when it last changed.