Privacy Policy.
Last updated: 18 SEPT 2026
Athena Integrity respects your privacy. This policy explains how we collect, use and protect personal information when you visit our website, contact us or manage a professional relationship with us.
It covers website activity, initial enquiries and general business communications. Our investigation, intelligence, due diligence and related services may involve additional processing, explained in separate privacy information relevant to the engagement.
1. Who is responsible for your information?
Athena Integrity Limited is responsible for the personal information covered by this policy.
Company number: 17298534
In this policy, “Athena”, “we”, “us” and “our” refer to Athena Integrity Limited. We act as the controller for the processing described here, meaning we decide why and how personal information is used.
For privacy enquiries, contact: hello@athenaintegrity.com
2. Information we collect.
When you contact us, we may collect your:
• Name, organisation and role.
• Email address and telephone number.
• Enquiry and subsequent correspondence.
• Information about the support you or your organisation needs.
We may also receive your professional contact details from someone introducing or referring you to us, or from your organisation in connection with a potential engagement.
Our website and hosting services may collect technical information, including your IP address, browser and device details, visit times and security logs.
Providing information in an initial enquiry is voluntary. However, we may be unable to respond or assess your request without sufficient contact details and context.
Please keep initial enquiries general. Do not include names of people involved in allegations, evidence or sensitive case details. We will arrange an appropriate secure channel before discussing those.
3. How and why we use information.
We use personal information to respond to enquiries, assess whether we can help, arrange discussions, manage business relationships and maintain appropriate records.
Our lawful basis depends on the purpose:
| Purpose | Lawful basis |
|---|---|
| Responding to enquiries, discussing potential work and managing professional relationships | Our legitimate interests in communicating with contacts and operating our business. |
| Checking potential conflicts and recording engagement decisions | Our legitimate interests in maintaining independence, managing risk and keeping appropriate business records. |
| Entering into or performing a contract directly with you as an individual | Taking steps at your request before entering into a contract, or performing that contract. |
| Communicating with you as a representative of a client or supplier organisation | Our legitimate interests in managing that organisation’s relationship with Athena. |
| Operating and securing our website and communications | Our legitimate interests in maintaining reliable services and preventing misuse. |
| Meeting applicable legal requirements | Compliance with a legal obligation. |
| Sending relevant business updates | Consent where required, or our legitimate interests in maintaining professional relationships and explaining our services where permitted. |
When relying on legitimate interests, we assess whether the processing is necessary and whether your rights and interests outweigh ours.
Where we rely on consent, you can withdraw it at any time. This does not affect the lawfulness of processing before withdrawal.
4. Sensitive enquiries and casework.
Integrity concerns can involve health information, safeguarding matters, allegations of criminal conduct and other particularly sensitive information.
Please do not send detailed case material through a general website form or unsolicited email. If we receive it, we will assess what we can lawfully retain or use, restrict access as appropriate and decide whether it should be transferred securely or deleted.
Processing special category information or criminal offence information requires additional legal conditions and safeguards beyond an ordinary lawful basis.
For client casework, Athena may act as a controller, a processor acting on a client’s instructions, or have different responsibilities for different activities. The applicable arrangements depend on the work and must be reflected in the engagement documentation and relevant privacy information.
This website policy does not, by itself, describe all processing involving complainants, witnesses, investigation subjects or other people involved in a case.
5. Our use of aiTHENA.
We do not use aiTHENA or other AI tools to process website enquiries or initial correspondence.
Our practitioners use an early version of aiTHENA in client work while we continue to develop its capabilities. Where this involves personal information, the relevant casework privacy information explains how it is used, including any external providers and international transfers.
Every AI output is reviewed by Athena’s practitioners, who remain responsible for decisions and recommendations.
6. Cookies and website technologies.
We do not use analytics cookies, advertising cookies, marketing pixels or other tracking tools.
Our website may use strictly necessary technologies to operate securely and reliably.
If we introduce technologies requiring consent, we will request it before using them and provide a way to change your preferences. We will update this policy and any relevant cookie information to reflect those changes.
7. Marketing communications.
We may send relevant updates, insights or invitations about Athena’s work where permitted by law. We ask for consent where required.
You can object to direct marketing at any time. Use an unsubscribe option in our messages or email hello@athenaintegrity.com.
We may retain a limited record of your preference so that we can respect your request.
8. Who we share information with.
Where necessary for the purposes described in this policy, we may share relevant information with:
• Website, hosting, email, cloud and IT service providers.
• Specialist practitioners and contractors supporting an enquiry or engagement.
• Legal, accounting, insurance and other professional advisers.
• An organisation you represent, where necessary to manage its relationship with us.
• Regulators, courts or public authorities where disclosure is legally required or otherwise lawful and necessary.
• Someone you have asked us to involve.
We limit sharing to information needed for the relevant purpose. Where a supplier processes information on our behalf, we use appropriate contractual arrangements and security requirements.
We do not sell personal information.
9. International access transfers.
Members of Athena’s team may access and process personal information outside the United Kingdom when carrying out their work. This access remains subject to our confidentiality, security and data protection requirements.
Where we transfer personal information to organisations outside the United Kingdom, we use the protections required by applicable data protection law.
For information about relevant international processing arrangements and applicable safeguards, contact hello@athenaintegrity.com.
Where we use suppliers or contractors, we take reasonable steps to ensure personal information is handled securely and in line with data protection requirements.
10. How long we keep information.
We keep personal information only for as long as necessary for its purpose. We determine retention by considering:
• Whether an enquiry remains active or requires reasonable follow-up.
• Whether a professional relationship is ongoing.
• The need to retain proportionate records of conflicts and engagement decisions.
• Applicable legal, regulatory, contractual and insurance requirements.
• The need to establish, exercise or defend legal claims.
• Your marketing preferences.
When information is no longer needed, we delete it securely or anonymise it. Retention arrangements for investigation and other case records are addressed separately.
11. How we protect information.
We use technical and organisational measures appropriate to the information and its sensitivity. These include access restrictions, confidentiality requirements and secure methods of storing and sharing information.
No internet communication method is entirely risk-free. For sensitive matters, contact us first so that we can agree an appropriate channel.
12. Your rights.
Depending on the processing and applicable law, you may have the right to:
• Access your personal information.
• Correct inaccurate or incomplete information.
• Request deletion or restrict processing.
• Receive certain information in a portable format.
• Withdraw consent where we rely on it.
You also have the right to object to processing based on legitimate interests, on grounds relating to your circumstances. Your right to object to direct marketing is absolute.
To make a request, email hello@athenaintegrity.com. We may need to verify your identity before responding.
These rights are subject to legal conditions and exemptions. Where a restriction applies, we will explain it to the extent we are permitted to do so.
13. Complaints.
If you have concerns about our handling of personal information, contact hello@athenaintegrity.com so that we can investigate and respond.
You may also complain to the UK Information Commissioner’s Office without contacting us first:
Website: ico.org.uk/make-a-complaint
Depending on where you live or work, you may also have the right to complain to another relevant data protection authority.
14. Other websites.
Our website may link to third-party websites, including LinkedIn. Their privacy practices are governed by their own policies, which you should review before providing information.
15. Changes to this policy.
We will publish updates on this page and revise the date above. Where required, we will bring significant changes to your attention.