Principles
In setting out the Gyroscope International privacy policy we follow the six principles set out in The Data Protection Act:
1. We seek to be fair and lawful. This means we will:
a. Have legitimate grounds for collecting and using the personal data;
b. Not use the data in ways that have unjustified adverse effects on the individuals concerned;
c. Be transparent about how we intend to use the data, and give individuals appropriate privacy notices when collecting their personal data;
d. Handle people’s personal data only in ways they would reasonably expect; and
e. Make sure we do not do anything unlawful with the data.
2. We are clear about the purposes for which we use personal data:
a. To communicate Gyroscope International insights and thought leadership in the fields of sales, relationship management and business development with individuals whom we have reason to believe have an interest in these subjects because of their role and the organisation they work in;
b. To explore potential projects with these individuals and organisations;
c. To deliver projects with these individuals, the organisations and individuals they involve in the projects;
3. The personal data we process will be adequate, relevant and not excessive. This mean we ensure that we hold personal data about an individual that is sufficient for the purpose we are holding it for in relation to that individual. We do not hold more information than we need for that purpose. This is part of the practice known as “data minimisation”.
4. We recognise that personal data needs to be accurate and kept up to date.
5. We recognise that Personal data should not be kept for longer than is necessary.
6. We recognise that individuals have rights of access to any data we process. Basis for processing data
We have reviewed the lawful bases for processing data. and have carried out a Legitimate Interest Assessment (available for inspection on request) and have concluded that we can:
a. Identify a legitimate interest;
b. Show that the processing is necessary to achieve it; and
c. Balance it against the individual’s interests, rights and freedoms.
Sources of data
We hold very little historic personal data.
Where we hold personal data relating to individuals who have been or are involved in existing projects we are approaching each individual and gaining their agreement that we can send them content to support them in implementing the project while the project is continuing and for 12 months after the end of the project. After this period we will approach them again to enquire if they choose to receive ongoing content in the form of a monthly update and a quarterly newsletter.
Where the directors have personal professional contacts we will approach each individual to ask if they choose for us to hold limited personal data (Name, title, department, company, business address, email and phone number (business/mobile) for the purpose of updating them on trends in
“sales performance in a changing world”.
Where a contact wishes to introduce us to a colleague or a contact where there is a legitimate interest, we will approach that individual as above.
If an individual wishes to explore potential projects or options for co-operation we will seek their permission to process data during this process.
Where individuals will be involved in a live project e.g. being trained or working in the design phase we will approach them in advance explaining the purpose of processing data and our methodology.
Some individuals will approach us via our website and they will be asked for their agreement for us to process their personal data. The directors have extensive contacts on LinkedIn (see LinkedIn
Privacy Statement at https://www.linkedin.com/legal/privacy-policy It is our understanding that we are able to continue contact with LinkedIn connections and followers. However if we process any
data from LinkedIn contacts within Gyroscope International for reasons of legitimate interest (see above) we will seek their agreement.
Where we buy in lists from commercial sources for reasons of legitimate interest, we will ensure they are GDPR compliant and will inform the individuals that we are processing data.
Security
The main location for any data is our Microsoft Teams environment. We have reviewed the Freshsales security arrangements and are satisfied they are effective.
Other data is held on Gyroscope International computer system. The server is kept in a locked building with controlled access. Access to PCs is password protected as is access to any mobile devices. One back up disk is kept in a secure office. Personal data is not held on any data sticks etc.
In the rare instances that personal data is held as hard copy it is located in a secure office.
Third Parties
The only occasion when personal data will be communicated to third parties is where a Gyroscope International partner business is providing a service to a client e.g.individuals being coached using a virtual coaching tool. The client company is always informed of our requirement to share any employee data and their communications policies are followed.
Registration
Gyroscope International is registered with the ICO as a data processor. Registration number: UK ZB329324. The named contact is Richard Higham who can be contacted at richard.higham@Gyroscope International.com or through the company’s registered office 3 Startforth Road, Riverside Park, Middlesbrough TS2 1PT or by phone on +44 7712 588757.
Anti-Bribery and Anti-Corruption Policy
1. Overview
It is the policy of Gyroscope International to conduct all business in an honest, transparent and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever we operate. We are committed to implementing and enforcing effective systems to counter bribery and corruption.
Gyroscope International will uphold all laws relevant to countering bribery and corruption in the jurisdictions in which we operate. We remain bound by the laws of the United Kingdom, including the UK Bribery Act 2010, in respect of our conduct both at home and abroad.
Bribery and corruption are serious criminal offences and may result in substantial penalties for individuals and organisations, including imprisonment, financial penalties, exclusion from public contracts and reputational damage. Gyroscope International therefore takes its legal and ethical responsibilities very seriously.
2. Who is Covered by this Policy?
This policy applies to:
a. Associated Persons
All individuals working at all levels and grades including directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, secondees, homeworkers, casual workers, agency staff, volunteers, interns, agents, sponsors, affiliates and any other persons associated with Gyroscope International, wherever located.
b. Third Parties
Where Gyroscope International engages with third parties, we will take appropriate and proportionate steps to encourage compliance with the principles set out in this policy.
3. What are Bribery and Corruption?
Corruption is the misuse of entrusted power or position for private gain.
A bribe is an inducement, payment, reward or advantage offered, promised, requested or accepted in order to gain any commercial, contractual, regulatory or personal advantage.
4. What is Not Acceptable?
Gyroscope International does not permit, and will not knowingly procure or authorise, any person associated with the business to:
a.
Give, promise, offer or authorise a payment, gift, hospitality or other advantage with the expectation or hope that a business advantage will be received or retained, or to reward a business advantage already given;
b.
Give, promise or offer any payment, gift or hospitality to a government official, public authority representative or other person to facilitate or expedite a routine procedure or decision;
c.
Accept any payment, commission or advantage from a third party where it is known or suspected that it is offered with the expectation of obtaining an improper business advantage;
d.
Accept gifts, hospitality or other benefits from third parties where there is reason to believe that these are intended to improperly influence business decisions;
e.
Threaten, retaliate against or disadvantage any person who refuses to commit a bribery offence or who raises concerns under this policy; or
f.
Engage in any activity that may lead to a breach of this policy or applicable anti-bribery laws.
5. Facilitation Payments and Kickbacks
Gyroscope International does not make, and will not accept, facilitation payments or kickbacks of any kind.
Facilitation payments are typically small, unofficial payments made to secure or expedite routine government actions.
Kickbacks are payments or benefits provided in return for a business favour or improper commercial advantage.
We avoid any activity that might lead to, or appear to suggest, that a facilitation payment or kickback may be made or accepted.
6. Donations
Gyroscope International does not make contributions to political parties.
Any charitable donations made by or on behalf of the business must be lawful, ethical, transparent and properly authorised.
7. Internal Controls
Gyroscope International maintains proportionate internal controls designed to prevent, identify and address bribery and corruption risks. These controls may include:
• Appropriate approval processes for significant expenditure and supplier payments;
• Separation of commercial approval and payment authorisation responsibilities where practical;
• Written contracts and statements of work for client and supplier engagements;
• Maintenance of accurate financial records and expense documentation;
• Review of unusual or high-risk transactions or requests;
• Periodic review of compliance arrangements by senior management.
Gifts or hospitality above a reasonable and proportionate value should be declared to management.
8. Raising Concerns and Whistle-Blowing
Gyroscope International encourages employees, contractors, affiliates, suppliers and other third parties to raise concerns regarding suspected bribery, corruption or unethical conduct at the earliest opportunity.
Concerns may be raised confidentially via:
compliance@gyroscopeinternational.com
directly with Richard Higham, Chairman or another director.
All reports will be reviewed appropriately and treated seriously.
No individual who raises a genuine concern in good faith under this policy will suffer retaliation, discrimination, disadvantage or adverse treatment as a result of reporting their concerns. Reports will be handled confidentially wherever possible and disclosed only on a need-to-know basis.
9. Training and Awareness
Gyroscope International will provide periodic anti-bribery and anti-corruption awareness training appropriate to relevant roles and responsibilities.
Directors and account managers are required to acknowledge that they have studied these policies on an annual basis.
Relevant policies may also be shared with affiliates, contractors and business partners.
10. Responsibility, Monitoring and Review
Overall responsibility for the implementation and oversight of this policy rests with Richard Higham, Chairman.
Gyroscope International will monitor the effectiveness of this policy and review its implementation periodically to ensure its continued suitability, adequacy and effectiveness.
Improvements and updates will be made where appropriate to strengthen compliance arrangements and reflect changes in applicable law or business operations.
Gyroscope International
Anti-Money Laundering Policy
1. Overview
Gyroscope International is committed to complying with the ethical principles and legal requirements underpinning anti-money laundering legislation and counter-terrorist financing regulations.
While the nature of our business means the risk of exposure to money laundering activity is considered low, Gyroscope International recognises the importance of maintaining appropriate vigilance and ethical standards in all business relationships and financial transactions.
2. Scope
This policy applies to all directors, employees, consultants, contractors, affiliates and associated persons acting on behalf of Gyroscope International.
3. Policy Statement
All persons associated with Gyroscope International are expected to remain alert to any suspicious activity involving clients, suppliers or third parties.
Examples of suspicious activity may include:
• Requests for unusual payment arrangements;
• Payments from unrelated third parties;
• Requests to avoid normal invoicing or contractual processes;
• Unexplained or unusually complex transactions;
• Concerns regarding the legitimacy of funds or business activities.
Gyroscope International will maintain appropriate financial records and conduct business through transparent and properly documented commercial arrangements.
4. Reporting Concerns
Any person who knows or suspects that money laundering, fraud or terrorist financing activity may be taking place must report their concerns immediately via:
compliance@gyroscopeinternational.com
or directly to Richard Higham, Chairman.
All reports will be reviewed appropriately and handled confidentially wherever possible.
5. Protection for Individuals Raising Concerns
Gyroscope International will not tolerate retaliation or adverse treatment against any individual who raises a genuine concern in good faith regarding suspected unlawful or unethical conduct.
Reports will be handled sensitively and disclosed only where necessary for appropriate investigation or legal compliance.
6. Monitoring and Review
Gyroscope International will periodically review this policy to ensure it remains appropriate, proportionate and aligned with applicable legal and ethical requirements.
Health & Safety Policy
1. Overview
Gyroscope International is committed to providing a safe and healthy working
environment for employees, contractors, affiliates, clients and other persons who may be affected by our activities.
As a consultancy and professional services business, our operational health and safety risks are generally low. Nevertheless, we recognise our responsibility to comply with applicable health and safety legislation and to maintain appropriate and proportionate arrangements for managing health and safety risks.
Health and safety forms an important part of our overall commitment to responsible and professional business practice.
2. Responsibility
Overall responsibility for health and safety management and compliance with this policy rests with Richard Higham, Chairman.
Management will periodically review health and safety arrangements and encourage continuous improvement appropriate to the nature and scale of the business.
All employees, contractors and associated persons are expected to take reasonable care for their own health and safety and that of others affected by their actions.
3. Our Commitments
Gyroscope International is committed to:
• Providing appropriate control of health and safety risks arising from work
activities;
• Complying with applicable occupational health and safety legislation and
regulations;
• Consulting with employees and contractors on matters affecting health and
safety where appropriate;
• Providing information, instruction and reasonable supervision relating to
workplace safety;
• Ensuring individuals are appropriately competent for the activities they
undertake;
• Preventing accidents, incidents and work-related ill health where reasonably
practicable;
• Maintaining safe and healthy working conditions appropriate to the nature of the business;
• Encouraging safe working practices during travel, remote working and client site activities.
4. Risk Assessment and Safety Processes
Gyroscope International maintains proportionate processes to identify, assess and manage health and safety risks associated with its operations.
These processes may include:
• Periodic review of workplace and operational risks;
• Consideration of health and safety factors before introducing new equipment, technology, processes or working arrangements;
• Recording and reviewing any health and safety incidents or concerns;
• Taking corrective action where weaknesses or risks are identified;
• Considering health and safety requirements when working at client locations or third-party premises. Because the business does not undertake manufacturing, industrial processing or hazardous operational activities, health and safety risks are generally considered low and are managed proportionately.
5. Training and Awareness
Gyroscope International will provide appropriate health and safety information and awareness relevant to the nature of the work being undertaken. This may include:
• Induction or onboarding guidance;
• Remote working and workstation awareness;
• Travel and client-site safety considerations;
• Periodic reminders regarding safe working practices;
• Guidance relating to incident reporting and emergency procedures.
Health and safety awareness may be incorporated into periodic management
communications and training activities where appropriate.
6. Monitoring and Performance
Gyroscope International will periodically review health and safety practices and may use simple operational indicators appropriate to the business, including:
• Incident or accident reports;
• Reported health and safety concerns;
• Completion of relevant awareness activities;
• Review of recurring operational risks.
The business seeks to maintain a proactive approach to continuous improvement in health and safety performance.
7. Protective Equipment
The normal activities of Gyroscope International do not generally require the routine use of specialist personal protective equipment (PPE).
Where activities at client sites or third-party locations require PPE or adherence to specific safety procedures, individuals will be expected to comply with those requirements.
8. First Aid and Emergency Arrangements
As a primarily office-based and remote-working consultancy business, Gyroscope International maintains proportionate first aid and emergency arrangements appropriate to the nature of its activities.
Employees and contractors are encouraged to familiarise themselves with emergency procedures applicable to their working environment, including client locations and serviced office facilities where relevant.
9. Monitoring and Review
This policy will be reviewed periodically to ensure it remains appropriate, practical and aligned with applicable legal and ethical standards.
Gyroscope International will continue to seek reasonable and proportionate
improvements to its health and safety arrangements as the business develops.
Environmental Policy
1. Overview
Gyroscope International is committed to conducting business responsibly and in a manner that minimises environmental impact wherever reasonably practicable.
As an international consultancy and professional services business, our direct
environmental impact is relatively low. Nevertheless, we recognise our responsibility to operate sustainably, comply with applicable environmental laws and regulations, and encourage environmentally responsible practices within our operations and supply chain.
Environmental responsibility forms part of our broader commitment to ethical and sustainable business practice.
2. Responsibility
Overall responsibility for environmental management and compliance with this policy rests with Richard Higham, Chairman.
Management will periodically review environmental practices and encourage
continuous improvement appropriate to the size and nature of the business.
3. Our Commitments
Gyroscope International seeks to:
• Comply with applicable environmental legislation and regulations;
• Reduce unnecessary consumption of energy, paper, materials and other
resources;
• Encourage remote collaboration and virtual delivery where commercially and
operationally appropriate;
• Consider environmental impact when planning travel, logistics and project
delivery;
• Promote responsible purchasing and supplier selection practices;
• Reduce waste and encourage recycling wherever practical;
• Support digital working practices that minimise unnecessary printing and
physical distribution;
• Work with suppliers and partners who demonstrate appropriate environmental
responsibility.
4. Environmental Management Processes
Gyroscope International maintains proportionate processes appropriate to the nature and scale of its activities, including:
• Periodic review of environmental practices by management;
• Consideration of environmental factors in operational and supplier decisions;
• Encouragement of environmentally responsible behaviours among employees, contractors and affiliates;
• Maintenance of digital systems and remote working practices that reduce travel and material consumption;
• Appropriate disposal and recycling of business waste where applicable.
Because the business does not undertake manufacturing, industrial processing or hazardous operational activities, the environmental risks associated with soil
contamination, water pollution, air pollution, harmful emissions and hazardous
substances are considered low.
5. Objectives and Awareness
Gyroscope International aims to improve environmental performance through practical and proportionate measures including:
• Reducing unnecessary business travel where suitable alternatives exist;
• Increasing the use of digital documentation and collaboration tools;
• Raising awareness of environmentally responsible working practices among
directors, employees and contractors.
Environmental awareness guidance may be incorporated into periodic management communications and training activities where appropriate.
6. Monitoring and Review
Gyroscope International will periodically review this policy and its environmental practices to ensure they remain appropriate, practical and aligned with applicable legal and ethical standards.
The business may use simple operational indicators such as paper usage reduction, remote delivery levels and travel reduction trends to help monitor environmental performance where appropriate.
Updated May 2026
Labour, Equality and Human Rights Policy
1. Overview
Gyroscope International is committed to conducting business responsibly, ethically and in accordance with applicable employment, equality, human rights and labour laws.
We are committed to creating a professional environment in which all individuals are treated fairly, with dignity and respect, and are able to contribute fully regardless of their background or personal characteristics.
As an international consultancy and professional services business, we recognise our responsibility to promote ethical working practices within our own operations and, where appropriate, within our supply chain and business relationships.
2. Responsibility
Overall responsibility for the implementation and oversight of this policy rests with Richard Higham, Chairman.
Management will periodically review employment practices, equality matters and
workplace standards to ensure they remain appropriate, lawful and aligned with the values of the business.
3. Equality, Diversity and Inclusion
Gyroscope International is committed to eliminating unlawful discrimination and
promoting equality, diversity and inclusion throughout the business.
We do not discriminate on the grounds of:
• Gender;
• Gender reassignment;
• Marital or civil partnership status;
• Race;
• Ethnic origin;
• Colour;
• Nationality or national origin;
• Disability;
• Sexual orientation;
• Religion or belief;
• Age; or
• Any other protected characteristic under applicable law.
All employees, contractors, affiliates and associated persons will be treated fairly and with respect.
Selection for recruitment, engagement, promotion, training, progression and other opportunities will be based on aptitude, skills, experience and ability.
We are committed to:
• Creating an environment in which individual differences and contributions are
recognised and valued;
• Promoting dignity, inclusion and mutual respect;
• Not tolerating bullying, harassment, intimidation or victimisation of any kind;
• Providing fair access to development and progression opportunities;
• Reviewing practices periodically to promote fairness and equality.
4. Employee Voice and Raising Concerns
Gyroscope International encourages open communication and constructive feedback.
Employees, contractors, affiliates and associated persons may raise concerns,
feedback or complaints without fear of retaliation or disadvantage.
Concerns may be raised confidentially via:
compliance@gyroscopeinternational.com
or directly with Richard Higham, Chairman.
All concerns will be treated seriously and handled appropriately and confidentially wherever possible.
5. Prevention of Abuse and Mistreatment
Gyroscope International is committed to maintaining a work environment free from:
• Physical abuse;
• Sexual harassment or abuse;
• Mental or psychological abuse;
• Verbal abuse;
• Threats, intimidation or coercion;
• Bullying or degrading treatment.
No form of abusive or inappropriate conduct will be tolerated.
Appropriate action will be taken where behaviour is found to breach this policy.
6. Forced Labour, Modern Slavery and Human Trafficking
Gyroscope International rejects all forms of:
• Forced labour;
• Compulsory labour;
• Bonded labour;
• Human trafficking; and
• Modern slavery.
We will not knowingly work with organisations or individuals involved in such practices.
Employment and engagement relationships must always be voluntary and lawful.
As a consultancy business, Gyroscope International does not employ private or public security services in connection with its operations.
7. Child Labour
Gyroscope International is committed to complying with applicable legislation and recognised international standards relating to minimum working age and the protection of children.
We do not knowingly employ or engage child labour or support exploitative labour practices involving children.
Where recruitment or engagement processes are undertaken, reasonable steps will be taken to confirm eligibility to work and compliance with applicable age requirements.
8. Working Conditions, Working Hours and Remuneration
Gyroscope International is committed to fair and lawful working practices.
We seek to ensure that:
• Working hours and remuneration comply with applicable legal requirements;
• Individuals receive fair and reasonable remuneration for the work performed;
• Equal remuneration principles are respected for work of equal value;
• Working relationships are conducted professionally and respectfully.
As a professional services business, many working arrangements involve flexible and project-based structures. These arrangements will nevertheless be conducted lawfully and ethically.
9. Freedom of Association
Gyroscope International recognises and respects the rights of individuals to freedom of association and, where applicable by law, collective representation and bargaining.
The business will not knowingly interfere with lawful employee rights in these areas.
10. Local Communities and Land Use
Gyroscope International does not acquire or develop land, forests or water resources as part of its normal business activities.
The business is committed to operating responsibly and avoiding unlawful or unethical activities that could adversely affect local communities, livelihoods or natural resources.
11. Awareness and Proportionate Controls
Gyroscope International maintains proportionate controls and practices appropriate to the size and nature of the business, including:
• Periodic policy review by management;
• Appropriate recruitment and engagement practices;
• Clear standards of conduct and behaviour;
• Mechanisms for raising concerns;
• Management oversight of workplace practices;
• Periodic communication and awareness activities where appropriate.
12. Monitoring and Review
This policy will be reviewed periodically to ensure it remains appropriate, practical and
aligned with applicable legal and ethical standards.
Breaches of this policy may result in appropriate corrective action.
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