How Arable uses what you tell us

Who is responsible

Arable Consulting Ltd, 9 Ardross St, Inverness IV3 5NN, is responsible for your information (the “controller”). Contact us at team@arableco.com.

Why you have heard from us

Someone you know is being coached by Arable and has asked for a 360° review: a picture of how they come across to the people around them. They gave us your name, email address, how you know them and your country, so we could invite you.

What we collect

• Your name, email address, how you know the leader and your country, from the leader.
• What you say in the interview, saved as a written transcript, or your answers if you use the form.
• If you talk by voice, your audio is turned into text as you speak. It is not recorded or kept.
• Whether you have opened your link or finished, and whether our emails reached you.

How we use it

We use it to write one report for the leader that combines everyone's views, and in the leader's coaching. The report never names or quotes anyone and leaves out anything that could point to you. We also use your email address to send your invitation and up to two reminders.

If something you say suggests that you or someone else may be at risk, the interviewer shows you support options, and your coach and Arable's administrators are told that a transcript needs reading. We may contact you about it. If someone is in danger, we may need to act on what you said.

Who reads it

The coach running the 360, who is named in your invitation, and Arable's administrators. Arable will not share your transcript with the leader. If the leader asks us for the information we hold about them, we will withhold or remove anything that could identify you, as the law allows.

The AI interviewer

The interview is run by an AI tool built on ElevenLabs. It is not a person, and nobody listens or reads along live. After the conversation, an AI step picks out the three words you chose, how you described your relationship with the leader, and whether support options were shown. Your coach reads every transcript and writes the report, with help from Claude. No decision about you or the leader is made by AI.

Taking part is your choice

You don't have to take part, and saying no has no consequences for you. You can stop the conversation at any point, and whatever you said up to then is kept unless you ask us to delete it. If you work for Arable or for the leader, nothing you say is used in decisions about you.

Our legal basis is legitimate interests: supporting the leader's development through coaching. If you mention health or other sensitive details about the leader, we rely on the leader's explicit consent, given when they asked for the 360.

Who handles it for us

• Supabase stores the data, on servers in London.
• Vercel runs this website.
• ElevenLabs runs the interview, in the US. It uses AI models from Anthropic and Google to hold the conversation and to process the transcript afterwards.
• Resend sends our emails, from the US.
• Anthropic's Claude helps your coach write the report, in the US.

Where information goes to the US, it is protected by the UK-US data bridge or by the UK's approved contract terms for international transfers.

How long we keep it

Six months after the 360 closes, we delete your name, email address, transcript and answers. The leader's report, which does not identify you, is kept so their next review can be compared with it. ElevenLabs' copy of the conversation is deleted as soon as we have saved the transcript.

Your rights

You can ask for a copy of what we hold about you, ask us to correct or delete it, or object to how we use it. Email team@arableco.com. If you are unhappy with how we handle your information, you can complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint.

If you are the leader

We hold your name, email address, role and organisation, and the report. You will not receive anyone's transcript or answers. Your report stays with Arable so your next 360 can be compared with it; ask us at any time if you want it deleted.