At a glance
- We collect what we need to run our programmes, support you into work, partner with employers and meet our duties to funders and regulators.
- We never sell your personal data.
- Equality monitoring questions are optional. Answering or not answering them never affects your application.
- A person, not an algorithm, makes every decision about your place on a programme.
- Marketing is opt-in, and you can unsubscribe at any time.
- You can ask to see, correct or delete your data at any time by emailing compliance@niyo.co.
1. Who we are
This policy explains how Niyo Labs Ltd (“Niyo”, “we”, “us”, “our”), part of the Niyo group of companies, handles personal data. We are the controller of the personal data described here, which means we decide how and why it is used. We are registered with the Information Commissioner’s Office (ICO) under registration number ZB050051. Niyo Labs Ltd is registered in England and Wales under company number 11371368.
We follow the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR) and the Data (Use and Access) Act 2025.
This policy covers:
- visitors to our websites, including people who use Ask Niyo or the AI career map
- people who apply for, join or complete our programmes, including She Builds and our open cohorts
- users of Niyo Learn
- employers, SMEs, corporates, funders and other partners, and the people we deal with there
- mentors, coaches, speakers and volunteers
- job applicants
- people who sign up to our updates or attend our events
- young people who take part in Niyo Kidz activities, and their parents, guardians and teachers
Our employees receive a separate staff privacy notice. If a funder or partner runs a programme with us and is also a controller of your data, they will give you their own privacy notice as well.
Our Data Protection Officer (DPO) oversees how we handle personal data and answers questions about this policy, including requests to use your rights.
- Email
- compliance@niyo.co
- Post
- Data Protection Officer, Niyo Labs Ltd, UG05 Zellig Building, Gibb Street, Birmingham, B9 4AT, United Kingdom
If you need this policy in another format, such as large print, audio or plain text, please ask us.
3. The personal data we collect
Personal data is any information that identifies you, directly or indirectly. It does not include anonymised data. Depending on how you deal with us, we may collect:
| Type | Examples |
| Identity | Name, title, date of birth, gender, and photo ID where a funder requires it. |
| Contact | Email address, phone number and postal address, including postcode. |
| Application and eligibility | Your field and experience, education and qualifications, employment status, career goals, career map answers, and the evidence a funder needs to confirm you are eligible (for example, age, residency or right to work, and where you live). |
| Learning and progress | Attendance, assessments, coursework, capstone projects, Niyo Learn activity, feedback, certificates, and what you go on to do after the programme (for example, a new job, promotion or business). |
| Equality monitoring (optional) | Ethnicity, disability, and other characteristics we ask about to measure fair access. See section 6. |
| Support and safeguarding | Reasonable adjustments or access needs you tell us about, and information we record if there is a safeguarding concern. See section 6. |
| Employer and partner | Your name, role, organisation, work contact details, and details of the projects, briefs or vacancies you share with us. |
| Recruitment | Your CV, LinkedIn profile, cover letter, interview notes, references and right-to-work checks. |
| Payments | Billing name and address, and a record of the payments you have made. Card payments are handled by our payment provider, and we do not see or store your full card number. If you pay in instalments, our finance partner Payl8r handles your finance application and repayments. |
| Marketing and communications | Your marketing preferences and your correspondence with us. |
| Technical and usage | IP address, device and browser type, the pages you visit, and preferences such as light or dark mode. |
| AI interactions | The questions you type into Ask Niyo and the answers you give in the AI career map. |
| Images and stories | Photos, video and recordings from sessions and events, and testimonials you choose to give us. |
If you do not give us information we need for a contract or a legal requirement (for example, the evidence a funder needs to confirm you are eligible), we may not be able to offer you a place on that programme. We will always tell you when this is the case.
4. Where we get your data
- From you, when you fill in a form, apply, use Niyo Learn, take part in a programme, attend an event, email us or talk to us.
- From partners who refer you, such as employers, funders, local authorities, combined authorities, Jobcentre Plus and community organisations.
- From employers who sponsor or second you onto a programme, or who interview you through Demo & Hire.
- From public sources, such as LinkedIn and Companies House, for business contacts.
- From our technology, such as our website, Niyo Learn and our email tools, through cookies and similar technologies (see section 10).
5. How we use your data and our lawful bases
We only use personal data when the law allows us to. For each purpose, we rely on one of the following lawful bases under Article 6 of the UK GDPR:
- Contract: we need the data to give you a service you have asked for, or to take steps before entering into a contract with you.
- Legal obligation: the law requires us to use the data.
- Legitimate interests: we use the data for our reasonable business interests, or those of a third party, in a way you would expect and that does not override your rights. You can ask us for the balancing test we carried out.
- Consent: you have clearly agreed. You can withdraw consent at any time, and this does not affect anything we did before you withdrew it.
- Public task: in some funded programmes, we use data to carry out a task in the public interest on behalf of a public body.
| What we do | Lawful basis |
| Answer your enquiries and send you information you ask for | Legitimate interests; contract |
| Assess your application and eligibility, and enrol you | Contract; legal obligation or public task, where a funder sets eligibility rules |
| Deliver programmes, coaching and Niyo Learn, and track your progress | Contract |
| Introduce you to employers and arrange interviews or projects | Contract, with your agreement for each introduction |
| Report to funders and regulators, and allow audits and inspections | Legal obligation; public task; legitimate interests |
| Follow up on your progress, career and outcomes after the programme | Legitimate interests; legal obligation, where a funder requires it |
| Keep learners safe and meet our safeguarding and Prevent duties | Legal obligation; legitimate interests; vital interests, in an emergency |
| Make reasonable adjustments | Legal obligation (Equality Act 2010) |
| Monitor equality of access and outcomes | Legitimate interests; consent, where we ask for it |
| Work with employers, SMEs and partners | Contract; legitimate interests |
| Recruit staff, mentors and associates | Contract (steps before entering into one); legal obligation (right-to-work checks) |
| Take payments, keep accounts and prevent fraud | Contract; legal obligation |
| Send marketing and updates | Consent; legitimate interests, for business contacts and the “soft opt-in” (see section 9) |
| Run, secure and improve our website, Ask Niyo and Niyo Learn | Legitimate interests |
| Use photos, video and testimonials in our communications | Consent |
| Handle complaints and legal claims | Legitimate interests; legal obligation |
Change of purpose. We only use your data for the purpose we collected it for, or for a purpose that is compatible with it. If we need to use it for an unrelated purpose, we will tell you first and explain our lawful basis.
6. Sensitive data
Some information is given extra protection by law. This includes ethnicity, health and disability, religion, sexual orientation, and data about criminal convictions. We only collect it when we need to, and we protect it with extra safeguards.
- Equality monitoring. We ask optional questions to check that our programmes reach and serve people fairly, and to report anonymised figures to funders. You can choose “prefer not to say”. We rely on the substantial public interest condition for equality of opportunity or treatment (Data Protection Act 2018, Schedule 1, paragraph 8), or on your explicit consent where we ask for it.
- Health, disability and access needs. We use what you tell us to make reasonable adjustments and support you. We rely on our obligations under the Equality Act 2010, or on your explicit consent.
- Safeguarding. If we are worried about your safety or someone else’s, we may record and share information with the right authorities. We rely on the safeguarding of children and individuals at risk condition (Data Protection Act 2018, Schedule 1, paragraph 18) and, where relevant, our Prevent duty.
- Criminal records. We only carry out criminal record (DBS) checks for roles that legally require them, such as staff and mentors working with young or vulnerable learners, and in line with the law.
We keep an appropriate policy document that explains how we comply with the law when we rely on these conditions. You can ask us for a copy.
7. Funded programmes
Many of our programmes are funded by government and industry partners, including Innovate UK. Funders need certain information to check eligibility, pay for places, measure results and prevent fraud. For funded programmes, we may share your data with:
- the funder of your programme, such as the Department for Education, Innovate UK, the Department for Science, Innovation and Technology, or a combined authority
- the Learner Records Service, where a programme requires a Unique Learner Number
- Ofsted, for inspections
- auditors and evaluators the funder appoints
These organisations may use the data as controllers in their own right, under their own privacy notices. Before you enrol, we will tell you who funds your programme and point you to their notice. Funders may also contact you after the programme to ask how it helped you.
8. AI and automated decisions
We use AI to make our services more useful, for example in Ask Niyo, the AI career map and parts of Niyo Learn.
- What you type is sent to our AI service providers to generate a response. They act as our processors, under contracts that stop them using your data to train their own models.
- Please do not enter sensitive personal information, such as health details, into Ask Niyo.
- AI answers can be wrong. For anything binding, email info@niyo.co.
- The career map suggests programmes based on your answers. These are recommendations only.
- We do not make decisions about you that have legal or similarly significant effects (such as accepting or rejecting an application) using solely automated processing. A member of our team reviews every application.
- If we ever introduce significant automated decision-making, we will tell you first, explain how it works, and give you the right to have a person review it, to give your views, and to challenge the decision.
9. Marketing
We only send marketing emails or texts to individuals who have opted in, or who have bought or applied for a similar service from us and did not opt out at the time (the “soft opt-in”). We may send relevant updates to business contacts at their work email address, based on our legitimate interests.
Every message includes an unsubscribe link. You can also email compliance@niyo.co at any time. When you unsubscribe, we keep your email on a suppression list so we do not contact you again. Unsubscribing does not affect messages we need to send about a programme you are on.
We never sell your personal data, and we do not share it with third parties for their own marketing.
10. Cookies and similar technologies
Our website stores a small amount of information on your device. For example, it remembers whether you chose light or dark mode. Storage like this is strictly necessary to provide something you asked for, so it does not need your consent.
We only use non-essential cookies, such as for advertising, with your consent. Where the law allows, we may use analytics to understand how our site is used and improve it. If we do, we will tell you clearly and give you a simple way to say no. Our cookie policy lists the cookies we use.
11. Who we share your data with
We share personal data only when we need to, and only as much as is necessary:
- Service providers (processors) who work for us under contract and only on our instructions. These cover cloud hosting, our CRM and email platforms, our learning platform, video calls, payments, HR and recruitment, AI services, IT support and security.
- Employers and partners involved in your programme, such as when we introduce you for an interview, a live brief or Demo & Hire. We share only what is needed, and we tell you before we do.
- Payl8r, our finance partner, if you choose to spread the cost of a programme. Social Money Ltd t/a Payl8r is a separate controller. It will carry out identity, credit and affordability checks, and handle your application under its own privacy notice. We share only the details needed to set up your plan, such as your name, contact details and the programme cost, and Payl8r tells us whether your plan is approved and how payments are going.
- Funders, regulators and inspectors, as described in section 7.
- Other Niyo group companies, where they help deliver a service to you.
- Professional advisors, such as lawyers, accountants, auditors and insurers.
- Police, courts and other authorities, when the law requires it, to protect someone from harm, or to establish or defend legal claims.
- A buyer or investor, if we sell, merge or restructure all or part of our business. Your data would remain protected under this policy, and we would tell you about any change of controller.
12. International transfers
We store and process personal data mainly in the UK and the European Economic Area. Some of our service providers may process data in other countries, such as the United States. When data leaves the UK, we make sure it is protected. We do this either by transferring it to a country the UK has approved as having adequate protection (including US organisations certified under the UK Extension to the EU–US Data Privacy Framework), or by using the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with a transfer risk assessment. You can ask us for details of these safeguards.
13. How we protect your data
We are Cyber Essentials certified, which means our security controls have been independently checked against the UK Government’s cyber security standard. Our measures include:
- encryption in transit and, where available, at rest
- role-based access and multi-factor authentication
- confidentiality obligations for everyone who works for us
- regular data protection training
- careful checks on the suppliers we use
No system is completely secure, but we work hard to protect your data and we keep our measures under review. If a personal data breach happens, we will report it to the ICO within 72 hours where the law requires us to. If the breach is likely to put your rights at high risk, we will tell you without undue delay.
14. How long we keep your data
We keep personal data only for as long as we need it for the purpose we collected it for, including to meet legal, accounting, funder and reporting requirements. Our standard retention periods are:
| Data | How long we keep it |
| General enquiries | 2 years after our last contact with you |
| Applications that do not lead to a place | 12 months after the decision |
| Learner records for funded programmes | The period your funding agreement requires, usually 6 years after the end of the programme, and longer if a funder or auditor requires it |
| Learner records for other programmes | 6 years after the end of the programme |
| Financial and payment records | 6 years after the end of the financial year they relate to |
| Job applications that are not successful | 6 months after the decision, or 12 months with your consent so we can consider you for future roles |
| Marketing preferences | Until you unsubscribe, then on our suppression list |
| Ask Niyo questions | Not saved to any learner record, and deleted within 30 days |
| Safeguarding records | As set out in our safeguarding policy |
| Photos, video and testimonials | Until you withdraw your consent, though we cannot recall printed materials that have already been published |
We may keep data for longer if there is a complaint, a legal claim or an investigation. When we no longer need data, we delete it securely or anonymise it.
15. Your rights
Under UK data protection law, you have the right to:
- Access: get a copy of your personal data and information about how we use it.
- Rectification: have inaccurate or incomplete data corrected.
- Erasure: have your data deleted where we have no good reason to keep it.
- Restriction: ask us to pause using your data, for example while we check its accuracy.
- Object: object to us using your data on the basis of legitimate interests or public task, and to direct marketing at any time.
- Portability: receive data you gave us in a commonly used, machine-readable format, or have it sent to another organisation.
- Withdraw consent: wherever we rely on your consent.
- Rights about automated decisions: see section 8.
To use any of these rights, email compliance@niyo.co. You do not usually need to pay. We may ask you to confirm your identity before we act. We will reply within one month. If your request is complex, or you make several requests, we may extend this by up to two more months, and we will tell you why. When you ask for a copy of your data, we will carry out reasonable and proportionate searches. If a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse it, and we will explain why. Some rights do not apply in every situation; for example, we may need to keep certain records for a funder. If a right does not apply, we will tell you why.
If you have a Niyo Learn account, you can view and update much of your information yourself, and close your account at any time.
16. Complaints
If you are unhappy with how we have handled your data, please tell us first so we can put it right. Email compliance@niyo.co. We will acknowledge your complaint within 30 days, investigate it, and tell you the outcome without undue delay.
You also have the right to complain to the Information Commissioner’s Office, the UK regulator for data protection, at ico.org.uk/make-a-complaint ↗ or on 0303 123 1113.
17. Young people and Niyo Kidz
Our main programmes. She Builds, our AI accelerators and Niyo Learn are for people aged 16 and over, and most funded places require applicants to be 19 or over. If a programme includes learners aged 16 or 17, we follow our safeguarding policy, give information in clear and age-appropriate language, and involve a parent or carer where that is appropriate.
Niyo Kidz (ages 11 to 18). Niyo Kidz runs assemblies, workshops, careers fairs and campaigns for young people aged 11 to 18, usually with schools, trusts and youth organisations.
- What we collect. Only what we need to run an activity safely: the young person’s first name, age or school year, school or group, attendance, any access or medical needs we are told about, and the name and contact details of a parent, guardian or teacher. Photos and video only with consent.
- Consent for under-16s. For children under 16, we ask a parent or guardian for consent before we collect personal data directly from the child (for example, to register for an activity or receive updates) and before we take or use photos or video.
- Activities run through a school. Where a school or trust organises the activity, it is usually the controller of pupil data. We use that data only on its instructions and under a data-sharing agreement.
- Ages 16 to 18. Young people aged 16 to 18 can give their own consent where the law allows. We still involve a parent or carer where that is appropriate.
- What we never do. We never use young people’s data for marketing, never sell it and never use it for automated decisions. Ask Niyo and the AI career map are not designed for under-16s.
- How long we keep it. Activity records are kept only as long as we need them for safeguarding and funder reporting (see section 14 and our safeguarding policy). Photos and video are kept until consent is withdrawn.
- Safeguarding contact. If you have a concern about a young person, or a question about their data, email compliance@niyo.co. Read our safeguarding policy.
We do not knowingly collect personal data directly from children under 16 without a parent’s or guardian’s consent. If you think we have, please contact compliance@niyo.co and we will delete it.
18. Other websites
Our site links to other websites, such as funders, certification registries and event platforms. We are not responsible for how they handle your data, so please read their privacy notices.
19. Changes to this policy
We review this policy regularly. If we make significant changes, we will post them here and, where appropriate, tell you by email before they take effect. This version was last updated on 14 October 2026.
Social value
Social value you can prove.
Fund places, mentor teams and host placements. We map every outcome to the government's Social Value Model, so your bids and reports carry evidence.
New skills. New jobs.
People trained, accredited and placed into paid roles, tracked at 3, 6 and 12 months.
Fair access to AI careers.
Funded places for women moving into AI, with progress tracked from day one.
Stronger small businesses.
Real AI projects delivered for SMEs in your supply chain or community.
Aligned to PPN 002, the Social Value Model for central government contracts