Privacy Policy

Last updated: 29.04.2026

Contact details
About our services
What information we collect, use, and why
Lawful bases and data protection rights
Processing special category data
Where we get personal information from
How long we keep information
Who we share information with
How to complain

1. Contact Details

Archie McAlpine & Associates Ltd 702 Wright Building, 5 Marian Place, London, E2 9FU, United Kingdom.

Telephone: 07766727089 Email: arm@archiemcalpineassociates.com

2. About Our Services

Archie McAlpine & Associates Ltd ("AMA", "we", "us", "our") provides the following services:

Organisational wellbeing consultancy: Research, strategy, and programme design for corporate and institutional clients, including employee wellbeing surveys, quantitative and qualitative data analysis, and tailored wellbeing recommendations.

Health coaching: One-to-one coaching programmes for individual clients, focused on lifestyle optimisation, stress management, and personal wellbeing.

Neurofeedback and EEG assessment: Quantitative EEG (qEEG) brainwave assessments and personalised neurofeedback training programmes, including the My Brain at Rest (MBAR) programme delivered under the TrueBearing protocol. These services involve the use of an EEG headset to capture and analyse brainwave data, followed by tailored neurofeedback training designed to support cognitive performance and wellbeing.

3. What Information We Collect, Use, and Why

Individual client services (health coaching and neurofeedback)

We collect or use the following information to provide services:

Contact information (name, email address, telephone number)
Intake assessment and health history information, including current and past physical and mental health conditions, medications, lifestyle factors, and relevant personal history
EEG and brainwave data captured during assessments and sessions
Session notes and progress records
Photographs or video recordings (where relevant and with consent)
Call recordings (where relevant and with consent)
Payment information (processed securely via our payment provider; we do not store card details directly)

Special category data (individual clients)

Given the nature of our health coaching and neurofeedback services, we also collect and process the following special category data:

Health information, including physical and mental health history, diagnoses, and medication
Biometric information, including EEG and brainwave data captured during assessments and training sessions

We collect this data solely for the purpose of delivering safe, effective, and personalised services. We will never process your special category data without your explicit consent. See Section 5 for more detail.

Corporate client services (organisational wellbeing consultancy)

We collect or use the following information to provide services:

Workforce demographic data (e.g., department, tenure)
Employee wellbeing survey responses
Qualitative research data (e.g., focus group recordings and transcripts)
Racial or ethnic origin data (where provided voluntarily for research purposes)
Sexual orientation data (where provided voluntarily for research purposes)
Biometric information (where used to identify someone)

Research or archiving purposes

Recorded images, such as photos or videos
Call recordings
Personal information used for research purposes
Records of consent, where appropriate
Racial or ethnic origin data
Biometric information
Health information
Sexual orientation data

4. Lawful Bases and Data Protection Rights

Under UK data protection law, we must have a "lawful basis" for collecting and using your personal information. You can find out more about lawful bases on the ICO's website.

Your data protection rights

Right of access — You may request copies of your personal information and details about how we use it.
Right to rectification — You may ask us to correct or update inaccurate or incomplete information.
Right to erasure — You may ask us to delete your personal information, subject to applicable exemptions.
Right to restriction — You may ask us to limit how we use your personal information.
Right to object — You may object to certain types of processing.
Right to data portability — You may ask us to transfer your personal information to another organisation.
Right to withdraw consent — Where consent is our lawful basis, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

We must respond to any request within one month. To exercise any of these rights, please contact us using the details in Section 1.

Our lawful bases

For individual client services (health coaching and neurofeedback):

Consent — We collect your personal information on the basis of your explicit written consent, obtained before services commence through our client intake process. You may withdraw consent at any time.
Contract — We collect and use the information necessary to fulfil our contractual obligations to you.
Legitimate interests — Where relevant, we rely on legitimate interests such as maintaining records for service continuity and quality, balanced against your rights and interests.

For corporate client services (organisational wellbeing consultancy):

Consent — Participant data is collected with individual consent through our survey and research processes.
Contract — We collect and use information to fulfil our contractual obligations to the commissioning organisation.
Legal obligation — We comply with applicable law regarding record-keeping.
Legitimate interests — We collect data regarding demographics, wellbeing scores, and aspects of company culture, environmental design, and individual health, to create customised wellbeing strategies for the workforce.

For research or archiving purposes:

Consent
Contract
Legal obligation
Legitimate interests (as above)

5. Processing Special Category Data

Where we process special category personal data — including health information and biometric/EEG data — we do so on the basis of your explicit consent under Article 9(2)(a) of the UK GDPR.

This consent is collected separately from general service consent, via our client intake and consent process, before any assessment or session commences.

You have the right to withdraw your consent to the processing of your special category data at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal. Please note: if you withdraw consent to the processing of health or EEG data, we may be unable to continue providing neurofeedback or health coaching services safely.

6. Where We Get Personal Information From

Directly from you, via our intake forms, in-session assessments, emails, or telephone contact.

From assessment tools and platforms, including:

BrainBit Flex EEG headset — hardware used for brainwave data capture during neurofeedback assessments and sessions
TheraQ / Divergence — neurofeedback software and protocol management platform
SurveyMonkey — workforce wellbeing surveys for corporate clients (SOC 2 accredited, HTTPS/TLS encrypted; participant data is pseudonymised where appropriate)
Otter — AI transcription software used for qualitative research recordings (SOC 2 Type 2 certified; data is not sold and complies with UK GDPR and applicable privacy standards)

7. How Long We Keep Information

Individual client data (health coaching and neurofeedback)

Client records — including intake assessments, session notes, EEG data, consent records, and correspondence — are retained for seven (7) years following the conclusion of your programme or last contact with us. This reflects the limitation period under the Limitation Act 1980 and the need to maintain accurate records in the event of any future query or complaint. After this period, all records are permanently and securely deleted.

Corporate client and research data

Quantitative datasets related to employee wellbeing are retained for ten (10) years for longitudinal research purposes. After this period, the data is permanently deleted. Clients who wish to continue working with us beyond this period will need to initiate a new research project.

Qualitative research recordings and transcripts — including focus groups — are retained for ten (10) years and stored securely via Otter.

All survey data is stored securely via SurveyMonkey, with data centres that are SOC 2 accredited and transmission protected by HTTPS/TLS encryption.

8. Who We Share Information With

Individual client data is not shared with any third party without your explicit consent, except:

Where we are required to do so by law (for example, safeguarding obligations or a court order)
Where you have provided explicit consent for onward sharing (for example, a referral to a third-party practitioner)

Corporate client and research data is shared with the commissioning organisation as part of our research consultancy deliverables, in accordance with the terms of the relevant client contract.

We do not sell your personal data. We do not transfer your data outside the United Kingdom without appropriate safeguards in place.

9. How to Complain

If you have any concerns about our use of your personal data, please contact us in the first instance using the details in Section 1.

If you remain unhappy after raising a complaint with us, you may complain to the Information Commissioner's Office (ICO):

Information Commissioner's Office Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Helpline: 0303 123 1113 Website: https://www.ico.org.uk/make-a-complaint