Privacy Policy

Last updated: 12 June 2026

OuterCircle is committed to protecting your privacy and handling your personal information responsibly, transparently and securely.

This Privacy Policy explains how we collect, use, store and share personal information when you visit our website, sign up to our community, register for events, complete forms, attend programmes, take part in surveys or research, subscribe to our communications, or engage with us as a student, apprentice, employer, training provider, school, partner, speaker, mentor, Emerging Leader, ambassador, volunteer, sponsor or supporter.

For the purpose of this Privacy Policy, “OuterCircle”, “we”, “us” and “our” means OuterCircle.

OuterCircle is the data controller for the personal information described in this Privacy Policy, unless we tell you otherwise.

If you have any questions about this Privacy Policy or how we use your personal information, please contact us at: outercircle@outer-circle.uk

1. Who we are

OuterCircle is an apprenticeship-focused organisation supporting young people to explore, access and thrive in apprenticeships. We also work with employers, training providers, schools and partners to improve apprenticeship attraction, readiness, retention, experience, progression and leadership development.

Our work includes community events, workshops, mentoring, Emerging Leader opportunities, apprenticeship readiness support, employer and training provider partnerships, research, insight reports, newsletters, digital community engagement and social mobility-focused programmes.

2. A simple summary for young people

We collect information so we can:

• help you join the OuterCircle community;
• invite you to events, programmes and opportunities;
• support you with apprenticeship-related guidance;
• understand what young people and apprentices need;
• improve our events, services and programmes;
• keep people safe and supported at our events;
• share anonymised impact data with partners, funders or sponsors.

We will not sell your personal information.

Where we ask for sensitive information, such as ethnicity, gender, disability, health, accessibility needs or background information, we will explain why we need it and, where required, ask for your consent.

If you are under 18 and do not understand anything in this policy, please ask a parent, guardian, teacher or trusted adult to help you.

3. Information we may collect

We may collect personal information directly from you when you:

• complete a form on our website;
• sign up to join the OuterCircle community;
• register for an event, workshop or programme;
• apply for an opportunity, programme or role through OuterCircle;
• apply to become an Emerging Leader, ambassador, mentor, speaker, volunteer or content creator;
• subscribe to our newsletter or updates;
• contact us by email, phone, social media or through our website;
• take part in surveys, interviews, focus groups or research;
• attend one of our events;
• engage with us as an employer, training provider, school, partner, sponsor or supporter.

The personal information we collect may include:

• your name;
• email address;
• phone number;
• age or age range;
• location, city or region;
• school, college, university, employer or training provider;
• apprenticeship status, career interests or sector interests;
• job title, organisation or professional details;
• event registration and attendance details;
• dietary, accessibility or support requirements where relevant;
• feedback, survey responses, interview responses or research contributions;
• photos, videos or audio recordings from events, where applicable;
• social media handles, where you choose to provide them;
• communication preferences;
• any other information you choose to give us.

We may also collect basic technical information when you use our website, such as your IP address, browser type, device information, pages visited and website usage data through cookies or analytics tools.

4. Diversity, background and special category data

In some cases, we may collect information that is considered more sensitive under data protection law. This may include information about:

• ethnicity;
• gender;
• disability;
• accessibility needs;
• health-related requirements;
• socioeconomic background;
• free school meal background or similar social mobility indicators.

We may collect this information to:

• understand the diversity and reach of our community;
• improve access and inclusion;
• monitor social mobility impact;
• provide appropriate support at events or programmes;
• understand barriers facing young people and apprentices;
• produce anonymised reports, statistics and impact summaries;
• report anonymised impact data to employers, training providers, schools, partners, funders or sponsors.

Where we collect special category data, we will only do so where we have a lawful basis under UK GDPR and a separate special category condition. Where required, we will ask for your explicit consent before collecting or using this information.

We will not use this information to make unfair decisions about you.

Where possible, we will anonymise or aggregate this information so individuals cannot be identified.

For example, we may tell a partner that a percentage of sign-ups or attendees came from a particular demographic group, such as age range, region, gender, ethnicity or socioeconomic background. We will not share names, contact details or individual-level sensitive information unless we have clearly explained this and have a lawful basis to do so.

5. Aggregated impact reporting

OuterCircle may use anonymised or aggregated data to report on the reach, diversity and impact of our work.

This may include reporting statistics such as:

• the number of people who signed up to a form or event;
• the percentage of attendees from particular age groups;
• the percentage of participants from different ethnic backgrounds;
• the percentage of participants from lower socioeconomic backgrounds;
• the regions or cities represented;
• feedback themes, confidence changes, engagement levels or event outcomes.

We may share this type of anonymised or aggregated information with employers, training providers, schools, partners, funders, sponsors, policymakers or other organisations we work with.

We will take care not to share information in a way that could reasonably identify an individual. Where numbers are very small, or where combining details could make someone identifiable, we may group categories together, remove detail or avoid sharing that statistic.

6. How we use your information

We may use your personal information to:

• manage your community membership or sign-up;
• process event, workshop or programme registrations;
• contact you about events, programmes, opportunities, updates or resources;
• deliver workshops, mentoring, community activities and programmes;
• provide apprenticeship-related guidance and support;
• match you with relevant opportunities, events or services;
• manage Emerging Leader, ambassador, mentor, speaker or volunteer activity;
• communicate with employers, training providers, schools and partners;
• manage partnerships, sponsorships and commercial relationships;
• collect feedback and improve our services;
• carry out research into the apprenticeship experience;
• produce anonymised reports, statistics and impact summaries;
• promote OuterCircle’s work, events and community impact;
• respond to enquiries or requests;
• manage safeguarding, health, safety or access needs;
• comply with legal, regulatory, administrative or accounting obligations.

7. Our lawful basis for using your information

We only use your personal information where we have a lawful basis to do so under UK data protection law.

Depending on the context, we may rely on:

Consent

For example, when you:

• sign up to receive marketing emails;
• agree to take part in research;
• give permission for photos, videos or testimonials to be used;
• provide special category data where explicit consent is required.

Contract or pre-contractual steps

For example, where we need to process information to provide an event, programme, service, opportunity or partnership that you or your organisation has requested.

Legitimate interests

For example, to:

• manage our community;
• improve our services;
• communicate with people who have engaged with us;
• understand our impact;
• build partnerships;
• invite relevant people to events or opportunities.

We only rely on legitimate interests where we believe our interests do not override your rights, freedoms or interests.

Legal obligation

For example, where we need to keep certain records or comply with applicable laws.

Vital interests or safeguarding reasons

In rare cases, we may use or share information where necessary to protect someone’s safety, welfare or wellbeing.

8. Young people and under-18s

OuterCircle works with young people, including people under the age of 18.

We aim to explain clearly how personal information is used and to only collect information that is necessary, proportionate and appropriate.

Where required, we may ask for parent, guardian, school, college or organisational involvement, particularly for younger participants or activities involving:

• safeguarding;
• media consent;
• event attendance;
• direct participation in programmes;
• research, surveys or interviews;
• sensitive personal information.

If you are under 18 and have any questions about how we use your information, you can contact us at outercircle@outer-circle.uk or ask a trusted adult to help you.

If you are a parent, guardian, teacher or safeguarding lead and have questions about how we process a young person’s information, please contact us.

9. Photos, videos and event content

At some OuterCircle events, we may take photos, videos or audio recordings for use in:

• event recaps;
• reports;
• social media;
• website content;
• marketing materials;
• sponsor or partner updates;
• impact communications.

Where appropriate, we will make attendees aware that photography or filming is taking place. We may also ask for specific consent, especially where content focuses on an identifiable individual, includes young people, or is intended for wider promotional use.

If you do not want to be photographed or filmed, please tell a member of the OuterCircle team at the event or contact us at: outercircle@outer-circle.uk

Where we use quotes, testimonials or case studies that identify you, we will usually ask for your permission first.

10. Research, surveys and impact reporting

We may invite you to complete surveys, interviews, polls, feedback forms or focus groups about your apprenticeship journey, event experience, career interests or views on the apprenticeship system.

We use this information to:

• improve our programmes and events;
• understand apprentice and learner experiences;
• produce reports and insights;
• inform employers, training providers, policymakers and partners;
• demonstrate our impact;
• support social mobility-focused work.

Where we share findings publicly or with partners, we will usually anonymise or aggregate the data so individuals cannot be identified, unless you have clearly agreed otherwise.

If we want to use your name, photo, quote, story or identifiable information in a public report, case study or promotional material, we will usually ask for your consent first.

11. Marketing and communications

We may contact you by email or other channels with updates about OuterCircle, events, opportunities, programmes, resources, community activity or relevant apprenticeship-related information.

You can unsubscribe from marketing emails at any time by using the unsubscribe link in our emails or by contacting us at: outercircle@outer-circle.uk

Even if you opt out of marketing, we may still contact you about important administrative matters, such as an event you registered for, a programme you are attending or a service you are receiving.

12. Who we may share your information with

We do not sell your personal information.

We may share your information with trusted third parties where necessary, including:

• event platforms and registration tools;
• email marketing providers;
• website, CRM or community platform providers;
• survey and form providers;
• payment or booking providers, where relevant;
• employers, training providers, schools or partners involved in a programme, opportunity or event you have engaged with;
• sponsors or funders, usually through anonymised or aggregated reporting;
• photographers, videographers or content partners;
• professional advisers, such as accountants, legal advisers or insurers;
• regulators, authorities or safeguarding contacts where required by law or safety concerns.

Where we share identifiable information with an employer, training provider, school, partner or sponsor, we will only do so where there is a clear reason and lawful basis.

Where possible, we share anonymised or aggregated information rather than identifiable personal information.

Where we use third-party service providers, we expect them to protect your information and only use it for the purposes we have agreed.

13. Employers, training providers, schools and partners

If you engage with OuterCircle on behalf of an employer, training provider, school, funder, sponsor or partner organisation, we may collect and use your professional contact details, such as your name, job title, organisation, email address and phone number.

We use this information to:

• respond to enquiries;
• manage meetings, proposals and partnerships;
• deliver services;
• coordinate events, workshops or programmes;
• manage contracts, invoices or commercial relationships;
• share relevant updates about OuterCircle’s work.

We may retain business contact information for a reasonable period where there is an ongoing relationship, potential partnership, previous engagement or legitimate business reason.

14. How long we keep your information

We only keep your personal information for as long as necessary for the purpose it was collected.

This may vary depending on the type of information and our relationship with you. For example:

• community membership records may be kept while you remain part of our community;
• event registration records may be kept for a reasonable period after the event;
• survey and research data may be kept for analysis and reporting, usually in anonymised or aggregated form where possible;
• consent records may be kept so we can evidence what you agreed to;
• financial, contract or partnership records may be kept for legal, accounting or audit purposes;
• marketing contact details are kept until you unsubscribe or ask us to remove them;
• safeguarding-related records may be kept for as long as necessary in line with safeguarding and legal responsibilities.

When we no longer need your information, we will delete, anonymise or securely archive it.

15. How we protect your information

We take appropriate steps to keep your personal information secure and protect it from unauthorised access, loss, misuse, alteration or disclosure.

This includes:

• using secure systems where possible;
• limiting access to people who need it;
• using reputable service providers;
• taking care when sharing information with partners;
• reviewing our processes as our organisation grows.

However, no website, email system or online platform can be guaranteed to be completely secure. You should take care when sharing personal information online.

16. International transfers

Some of the tools or platforms we use may process information outside the UK.

Where this happens, we will take reasonable steps to ensure appropriate safeguards are in place to protect your personal information in line with UK data protection law.

17. Your rights

Under UK data protection law, you have rights over your personal information. These may include the right to:

• access the personal information we hold about you;
• ask us to correct inaccurate or incomplete information;
• ask us to delete your information;
• ask us to restrict how we use your information;
• object to us using your information in certain circumstances;
• ask for your information to be transferred to another organisation;
• withdraw consent where we rely on consent.

You also have the right to object to us using your personal information for direct marketing at any time.

To exercise your rights, contact us at: outercircle@outer-circle.uk

We may need to verify your identity before responding to your request.

18. Cookies and website analytics

Our website may use cookies or similar technologies to help it function properly, understand how visitors use the site, improve user experience and measure performance.

Cookies may collect information such as your device type, browser, pages visited and how you interact with the website.

Where required, we will ask for your consent before using non-essential cookies.

You can usually manage or disable cookies through your browser settings.

If we use analytics, tracking pixels or marketing cookies, we will provide clear information about this through our cookie banner or cookie settings.

19. Links to other websites

Our website may contain links to other websites, platforms or services, such as event pages, partner websites, social media platforms, community platforms or application forms.

We are not responsible for the privacy practices of other websites. You should read their privacy policies before providing personal information.

20. Complaints

If you are unhappy with how we use your personal information, please contact us first so we can try to resolve the issue.

You can contact us at: outercircle@outer-circle.uk

You also have the right to complain to the UK Information Commissioner’s Office, the UK regulator for data protection.

Website: ico.org.uk

21. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our work, services, website, legal requirements or how we use personal information.

The latest version will always be available on our website.