Growth and Skills Levy · UK Advisory

You're paying the levy. HMRC is keeping the change.

96% of UK levy payers don't spend their full pot. £3.3 billion has expired back to HMRC since 2019. From August 2026, new contributions expire in 12 months — not 24. We make sure none of yours does.

Take control of your levy.

Active deadline
From 1 August 2026, new levy contributions expire in 12 months — half the current window. Most finance and HR teams are still working to the 24-month assumption. The window to recalibrate is now.
The problem most teams haven't priced in

Two parallel clocks. One missed deadline.

The Apprenticeship Levy was renamed the Growth and Skills Levy. From 1 August 2026, new contributions expire after 12 months — half the existing 24-month window. Funds in the account before that date follow the old rules through to their original expiry.

Most finance and HR teams are still planning against the old playbook. The result: workforce plans built around 24-month horizons that won't survive the new rule.

And critically: a signed contract with a training provider does not protect funds. Only a live commitment on the Apprenticeship Service platform stops the clock.

£3.3bn Returned to HMRC since 2019
96% Of payers don't spend their full pot
12 months New expiry window from August 2026
What changed — and why it matters now

The rules moved twice. Most playbooks haven't.

A side-by-side of what's changed under the Growth and Skills Levy reforms. If your last levy review pre-dates April 2025, every line below is new ground.

Expiry window
Was 24 months on all funds
Now 12 months on contributions from 1 August 2026 — half the time to act
Flexible spending
Was apprenticeships only
Now eligible: short courses, bootcamps, AI Leadership training
Transfer limit
Was 25% to any UK employer
Now 50% can be transferred — doubling your reach into supply chains, SMEs and charities
Minimum programme length
Was 12 months
Now 8 months with prior learning recognition
Level 7 funding
Was available to all ages
Now restricted to 16–21 from January 2026
Apprenticeship Units
Was not available
Launched April 2026 — including a 40-hour AI Leadership unit
What LevySmart does

Three services. One purpose: stop the leak.

We do one thing — help businesses take full control of their levy. Engage us for the audit, the management, the transfer brokering, or all three.

02 — Manage

Levy Management

We unlock your levy and connect it to the right activity — apprenticeships, flexible short courses, AI Leadership units — aligned to your workforce plan, then make sure the funds get put to work, on time and on plan.

  • Provider selection and procurement
  • Quarterly governance and reporting
  • Apprenticeship Service and ESFA compliance
03 — Transfer

Transfer Brokering

If you can't spend it, transfer it. We match unused levy to vetted SMEs and charities — turning expiring funds into measurable social impact under the new 50% transfer rule.

  • SME and charity vetting against your sector and ESG criteria
  • Full transfer documentation and platform setup
  • Fixed outcome fee on successful completion
How it works

Four steps. From discovery to delivery.

A short, defined engagement designed to fit around your finance and HR teams — not the other way round.

01

Discovery call

30 minutes. We understand the business, the headcount, the levy size, and what's already been tried.

02

Levy review

A review of your Apprenticeship Service account. You receive a written summary and a figure for funds at risk of expiry.

03

90-day plan

Prioritised roadmap: what to spend internally, what to transfer, what to book before the next expiry tranche.

04

Execute

We coordinate — providers, transfers, platform admin, board reporting. Ongoing or one-off, your choice.

Who else we work with

Two more audiences we work with.

You're already paying. The only question is whether you're spending it.

30 minutes. We'll tell you what's actually in your account.

Request a discovery call →
About LevySmart

We do one thing: help UK employers take full control of their levy.

A specialist advisory built around a single, focused service line — and a founder who has spent years helping organisations operate better, smarter and more efficiently.

Why LevySmart exists

The Apprenticeship Levy — now operating as the Growth and Skills Levy — was meant to be simple. UK employers with a payroll above £3 million pay 0.5% into a digital account, and use that account to fund apprenticeships and skills inside their business.

In practice, it's anything but simple. Funds expire on a rolling clock that's about to get shorter. Provider procurement is a maze. The rules have shifted — flexible short courses, AI Leadership Units, a 50% transfer cap, Level 7 age restrictions. Most finance and HR teams haven't been able to recalibrate.

"96% of levy payers don't spend their full pot. We exist to change that."

We listen first, then connect the parts that aren't talking, then build a plan that puts you back in control of your levy.

How we work

We are deliberately narrow. We do not do general HR consulting, broad L&D strategy, or fractional CHRO work. We do levy audits, levy management, and levy transfer brokering — and that's it.

How we think

Three values. One job: keep you in control of your levy.

01

Control.

Of where it goes.

You're paying the levy. We make sure you control where it goes — what it funds, when it's drawn down, and which clock it sits on.

02

Clarity.

On what's there.

A single document that tells you how much is in your levy account, how much expires in each of the next 24 months, and what you can do with it before it goes.

03

Cadence.

On what comes next.

A quarterly review of spend, expiry, and what's changed in the rules. The levy account doesn't sit still — neither does the plan.

The founder

LevySmart was founded by Harpreet Rai, who has spent his career in digital consulting — helping UK businesses and organisations operate more efficiently, deliver smarter outcomes, and get more value from the systems and frameworks they're already paying for.

Talk to Harpreet

Find out what's actually in your levy account.

Most conversations start with an audit. Most audits surface more than the client expected. Either way — you'll know.

Request a discovery call →
Get in touch

Tell us about your levy.

Send a short message and we'll come back to you. Most enquiries get a reply within one working day. If you'd rather start with email or LinkedIn, those details are further down.

Most enquiries get a reply within one working day. We don't share your details with third parties.

Or reach out directly
We typically respond within one working day.
For time-sensitive transfers nearing expiry, mark your message urgent and we'll prioritise.
Privacy

Privacy Policy

Last updated: 1 May 2026 · Version 1.0

Who we are

LevySmart is the trading name of Alturos Consulting Ltd, a company registered in England & Wales (Company No. 16613148). We help UK employers manage, spend, and transfer their Growth and Skills Levy funds.

For the purposes of UK data protection law, Alturos Consulting Ltd is the data controller for the personal data described in this policy.

We are registered with the Information Commissioner's Office (ICO) under registration number CSN3154575.

How to contact us about your data:
Email: hello@levysmart.com
Postal address: 1096 Uxbridge Road, Hayes UB4 8QH

If you contact us about your personal data, please put "Data request" in the subject line so we can respond within the statutory timeframe.

What this policy covers

This policy explains how we handle personal data in two contexts:

  1. Website visitors — anyone who visits levysmart.com, fills in our contact form, or emails us
  2. Client engagements — organisations and individuals who engage LevySmart for advisory services

It also covers prospective clients we contact directly as part of our business development activity.

What personal data we collect

From website visitors and people who contact us

When you fill in our contact form or email us, we collect:

  • Your name
  • Your work email address
  • The name of your organisation
  • The category of enquirer you've selected (e.g. levy-paying employer, training provider)
  • The content of your message
  • The date and time you contacted us

We do not use website analytics, advertising trackers, or session-recording tools. We do not log IP addresses for marketing purposes.

From clients during engagements

When you engage us for advisory services, we will additionally collect:

  • Names, job titles, and work contact details of relevant individuals at your organisation (typically in HR, finance, L&D, or executive functions)
  • Information about your Apprenticeship Service account, including levy contributions, expiry profiles, and existing commitments — accessed with your authorisation through your own platform credentials, which you control
  • Information about apprenticeship programmes, providers, and transfers being considered
  • Records of meetings, calls, and written correspondence

We do not collect personal data about apprentices or learners themselves. Where apprentice-level data appears in your Apprenticeship Service account, we work with aggregate figures and de-identified summaries.

From prospective clients

In the course of business development, we may hold the following information about individuals at organisations we have not yet engaged with:

  • Name, job title, and work email or LinkedIn profile of relevant decision-makers
  • The name of their employer and publicly available information about that employer (sector, headcount, levy size where disclosed)
  • Notes of any prior contact between us
  • The fact that the organisation appears, where applicable, on the public Transfer Register published by the Department for Education

We do not source personal data from data brokers or scrape personal data from social media. Prospecting data is sourced from public registers, company websites, professional networking platforms used for legitimate business contact, and B2B information services that are themselves UK-GDPR-compliant.

Why we collect it and the lawful basis

UK data protection law requires us to have a lawful basis for each type of processing. Here is ours:

What we doLawful basis (UK GDPR Article 6)
Respond to your contact form or email enquiryLegitimate interest (responding to your enquiry)
Deliver advisory services under an engagement letterPerformance of a contract with you
Hold and use prospecting data to make initial business development contactLegitimate interest (B2B contact about a specific regulated funding obligation)
Send follow-up information at your requestConsent
Send periodic updates to existing or recent enquirers about levy-related developmentsLegitimate interest (soft opt-in under PECR Regulation 22(3))
Keep records of engagements for tax, accounting, and regulatory purposesLegal obligation
Defend ourselves against complaints or legal claimsLegitimate interest

You can object to any processing based on legitimate interest — see "Your rights" below.

Our legitimate interest assessment for prospecting

We have considered the balance between our legitimate business interest in identifying organisations that may benefit from our services, and the privacy rights of the individuals we contact. Our prospecting:

  • Is B2B only — we contact individuals in their professional capacity at named employers, never in their personal capacity
  • Concerns a specific regulated funding obligation (the Apprenticeship/Growth and Skills Levy) that materially affects the employers we contact
  • Targets decision-makers in roles where this subject is reasonably part of their professional remit
  • Provides a clear opt-out in every initial contact
  • Is not high-volume — we contact a small number of organisations per month, with personalised outreach, not bulk email campaigns

We believe this balance falls in favour of legitimate interest. If you disagree, you can object at any time and we will stop.

Who else processes your data

We use the following service providers (data processors) to operate our business. Each is bound by a written agreement requiring them to protect your data and use it only for the purposes we specify.

ProcessorWhat they doWhere data is held
Cloudflare, Inc.Website hosting (Cloudflare Pages), DNS management, edge content deliveryGlobal edge network with UK / EU data centres prioritised for European traffic; corporate entity is US-based, with data transfers governed by the UK Addendum to EU Standard Contractual Clauses
Formspree, Inc.Contact form submission processing — receives the data you enter into our contact form and forwards it to our business email inboxUnited States, with data transfers governed by the UK Addendum to EU Standard Contractual Clauses. Formspree retains submission records for technical delivery diagnostics; we do not store contact form submissions on Formspree's platform beyond the period needed to deliver the message
Google (Google Workspace)Business email accounts (hello@ and harpreet.rai@levysmart.com)EU and UK data centres under standard contractual clauses

We do not use third-party analytics, advertising platforms, or marketing automation tools on the public website.

If we engage additional processors in future (for example, an accountancy practice or a CRM platform), we will update this policy accordingly.

We do not sell your data, share it with marketing partners, or use it to train AI models.

How long we keep your data

CategoryRetention period
Contact form submissions and email enquiries (no engagement)12 months from the date of last contact, then deleted
Active client engagement recordsDuration of engagement + 6 years (HMRC and limitation-period requirements)
Prospecting data (no contact made)12 months, then reviewed for relevance and either refreshed or deleted
Prospecting data (one or more contact attempts, no engagement)12 months from last contact, then deleted unless you have explicitly opted in to ongoing updates
Marketing opt-insUntil you withdraw consent, or 24 months without engagement, whichever is sooner
Records required by law (tax, accounting, regulatory)As required by the relevant law (typically 6 years for HMRC)

Where retention periods differ between categories, we apply the longest applicable period to a given record.

Where your data is held

The personal data described in this policy is held primarily within the United Kingdom or European Economic Area (EEA). Our email infrastructure (Google Workspace) holds data in EU and UK data centres.

Two of our processors involve transfers outside the UK/EEA:

  • Cloudflare (website hosting) is incorporated in the United States but routes European visitor traffic through its UK and EU edge data centres. Personal data primarily remains within the UK/EEA edge network.
  • Formspree (contact form processing) is a US-based service that receives form submissions and forwards them to our business email. Submission data transits through and is briefly retained on US infrastructure for delivery and diagnostic purposes.

Both transfers are governed by the UK Addendum to the EU Standard Contractual Clauses, which is the recognised legal mechanism for international personal data transfers under UK data protection law. If you would prefer not to use the contact form, you can email us directly at hello@levysmart.com, in which case only Google Workspace processes your data.

If we engage additional processors that involve material data transfers outside the UK/EEA, we will update this policy to disclose them.

Your rights

Under UK GDPR you have the following rights in relation to your personal data:

  • Access — ask for a copy of the personal data we hold about you
  • Rectification — ask us to correct data that is inaccurate or incomplete
  • Erasure — ask us to delete your data (subject to certain exceptions, such as data we must keep for tax or legal reasons)
  • Restriction — ask us to pause processing while a question is resolved
  • Portability — ask us to provide certain data in a structured, machine-readable format
  • Object — object to processing based on legitimate interest, including all prospecting and marketing
  • Withdraw consent — for any processing based on consent, you can withdraw it at any time
  • Complain to the regulator — you can complain to the Information Commissioner's Office at any time (ico.org.uk or 0303 123 1113), although we ask you to contact us first so we can try to resolve your concern directly

To exercise any of these rights, email hello@levysmart.com with "Data request" in the subject line. We will respond within one calendar month, as required by law. Most requests are free; we may charge a reasonable fee or refuse manifestly unfounded or excessive requests, in line with UK GDPR.

There is no charge for exercising your rights.

How we protect your data

We use industry-standard measures appropriate to the scale and nature of our business, including:

  • Encrypted connections (HTTPS) for all website traffic
  • Encrypted email and document storage via Google Workspace
  • Strong passwords and two-factor authentication on all business accounts
  • Access to client data restricted to the LevySmart team members directly involved in the engagement
  • Written data processing agreements with all service providers who handle personal data on our behalf
  • Regular review of security practices

No system is perfectly secure. If a personal data breach occurs that is likely to result in a risk to your rights, we will notify the ICO within 72 hours and notify affected individuals without undue delay, as required by UK GDPR.

Marketing communications

We will only send you marketing communications (newsletters, levy-related updates, service announcements) if:

  • You have explicitly consented to receive them, or
  • You are an existing or recent enquirer or client, the communication relates to similar services to those you have enquired about or engaged us for, and you have not opted out (this is the "soft opt-in" permitted by PECR Regulation 22(3))

Every marketing email we send will include a clear, free, one-click way to unsubscribe. You can also email hello@levysmart.com at any time to opt out.

We do not send marketing by SMS, automated phone calls, or fax.

Cookies

This website uses minimal essential resources to display correctly. We do not set tracking cookies, advertising cookies, or analytics cookies. See our Cookies Notice for details.

Children's data

LevySmart's services are aimed at organisational decision-makers in HR, finance, L&D, and executive roles. Our website is not directed at children, and we do not knowingly collect personal data from anyone under 18. If you believe we hold data about a child, please contact us and we will delete it.

Changes to this policy

We may update this policy from time to time to reflect changes in our practices, services, or the law. The "Last updated" date at the top of this page tells you when the current version took effect. Material changes (for example, adding a new processor or changing a retention period) will be flagged at the top of the policy for at least 30 days after the change.

If you have an active engagement with us, we will notify you of material changes by email.

How to complain

If you are unhappy with how we handle your data, please contact us first at hello@levysmart.com. We aim to resolve concerns within 14 days.

If you remain unhappy, you can complain to the Information Commissioner's Office:

  • Website: ico.org.uk
  • Phone: 0303 123 1113
  • Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow SK9 5AF
Cookies

Cookies Notice

Last updated: 1 May 2026 · Version 1.0

What this notice covers

This notice explains how levysmart.com uses cookies and similar technologies. It applies to anyone who visits the website. It works alongside our Privacy Policy, which explains how we handle personal data more broadly.

What cookies are

A cookie is a small text file that a website places on your device (computer, phone, tablet) when you visit. Cookies are widely used to make websites work properly, remember your preferences, or track your behaviour across sites for advertising.

UK and EU law (the Privacy and Electronic Communications Regulations, or PECR) requires that:

  • Websites tell you what cookies they use
  • Websites get your consent before setting any cookies that aren't strictly necessary

What cookies levysmart.com uses

We do not currently set any cookies on your device.

Specifically, this website does not use:

  • Analytics cookies (Google Analytics, Plausible, Matomo, or similar)
  • Advertising or marketing cookies (Meta Pixel, LinkedIn Insight Tag, Google Ads, or similar)
  • Social media tracking cookies
  • Session-recording or heatmap tools (Hotjar, Microsoft Clarity, or similar)
  • Third-party fonts or embedded resources that track you (we self-host all fonts and assets on our own server)

The only data the website processes is the information you actively submit through the contact form, which is covered in our Privacy Policy.

This means we do not display a cookie consent banner, because we have nothing to ask consent for. If at any point we add cookies that are not strictly necessary, we will add a banner before they are set, in line with PECR.

What happens if you submit the contact form

When you submit the contact form, your browser sends the information you have entered (name, email, organisation, message) to our form processor, Formspree, which forwards it to our business email inbox at hello@levysmart.com. See our Privacy Policy for full details on Formspree as a data processor.

The submission process does not set any cookies on your device. Your browser may briefly hold a record of the page you visited, but that is browser history, not a cookie set by us.

What might change in future

If we add any of the following in future, we will update this notice and add a clearly visible cookie consent banner that lets you accept or reject non-essential cookies before any are set:

  • A web analytics tool (we may add a privacy-respecting one such as Plausible or Fathom in future to understand visitor numbers, but we have not done so yet)
  • A scheduling or meeting-booking widget
  • A live chat or support tool
  • Embedded video or social media content

We will not add advertising or marketing tracking cookies. That is a deliberate choice and forms part of how we operate.

How to control cookies in your browser

Even though we don't set any, you can control cookies generally through your browser settings. Each browser handles this differently:

  • Chrome: Settings → Privacy and security → Cookies and other site data
  • Safari: Preferences → Privacy
  • Firefox: Settings → Privacy & Security
  • Edge: Settings → Cookies and site permissions

You can block all cookies, allow only first-party cookies, or delete existing cookies at any time.

The Information Commissioner's Office (ICO) has more general guidance at ico.org.uk/your-data-matters/online.

How to contact us about this notice

If you have any questions about cookies on this website, please email hello@levysmart.com.

Terms

Terms of Engagement

Effective date: 1 May 2026 · Version 1.0

These Terms of Engagement set out the basis on which Alturos Consulting Ltd (trading as LevySmart) provides advisory services to its clients. They apply to all engagements unless varied in writing.

1. Parties and definitions

1.1 The parties

These Terms govern the relationship between:

  • LevySmart — Alturos Consulting Ltd, a company registered in England & Wales with company number 16613148, whose registered office is at 1096 Uxbridge Road, Hayes UB4 8QH, referred to in this document as "we," "us," or "LevySmart"
  • The Client — the organisation named in the relevant Engagement Letter, referred to as "you" or "the Client"

1.2 Defined terms

In these Terms:

  • "Engagement Letter" means the written letter, email, statement of work, or proposal we issue to you setting out the specific scope, deliverables, timing, and fees for a particular piece of work
  • "Services" means the advisory services described in the Engagement Letter
  • "Deliverables" means any reports, documents, recommendations, plans, or other written outputs we provide to you in the course of the Services
  • "Apprenticeship Levy" means the UK Growth and Skills Levy (formerly the Apprenticeship Levy) administered by HMRC and managed via the Apprenticeship Service
  • "Apprenticeship Service Account" means the digital account operated by the Department for Education through which UK employers manage their levy funds and apprenticeship spending
  • "Confidential Information" has the meaning set out in clause 7

2. How an engagement begins

2.1 Engagement Letter

Each engagement begins when you confirm in writing your acceptance of an Engagement Letter we have issued to you. The Engagement Letter sets out:

  • The specific Services we will provide
  • The fees and payment terms
  • The expected timeline
  • Any specific deliverables, exclusions, or conditions

2.2 Order of precedence

If there is any conflict between an Engagement Letter and these Terms, the Engagement Letter prevails for the engagement it covers. These Terms apply to all matters not specifically addressed in the Engagement Letter.

2.3 No engagement without a Letter

We will not begin substantive work on a client matter until you have confirmed acceptance of an Engagement Letter in writing. Discovery calls, scoping conversations, and preliminary discussions before an Engagement Letter is signed are without charge and without contractual commitment on either side.

3. The Services

3.1 Service lines

LevySmart offers three service lines:

  • Levy Audit — a structured review of your Apprenticeship Service Account, including spend, expiry profile, and funds at risk, resulting in a written summary and prioritised action list
  • Levy Management — ongoing advisory support, including a periodic plan, quarterly reviews, and coordination of providers and transfers
  • Transfer Brokering — identification of suitable transfer recipients, coordination of the transfer process, and support with the documentation required by the Apprenticeship Service

The specific scope of each engagement is set out in its Engagement Letter.

3.2 What we do, and what we do not do

LevySmart is an advisory firm. We provide guidance, analysis, recommendations, and coordination. We do not:

  • Operate your Apprenticeship Service Account on your behalf, or hold the credentials to do so
  • Make payments, drawdown decisions, or contractual commitments to training providers in your name
  • Provide legal advice, tax advice, financial advice, or HR consultancy outside the scope of levy management
  • Guarantee any specific financial outcome, recovery of funds, or apprenticeship placement
  • Recover funds that have already expired and returned to HMRC — we work to prevent expiry, not to reverse it

Where any of the above are needed, we will identify the issue and recommend that you obtain appropriate specialist advice. We do not receive referral fees or commissions for any third-party referral we make.

3.3 Apprenticeship Service Account access

Where the Services require us to view information held in your Apprenticeship Service Account, you will provide that information to us in one of two ways:

  • by sharing screenshots, exports, or summaries from the account, or
  • by walking us through the relevant screens during a scheduled call

We do not require, request, or hold the login credentials to your Apprenticeship Service Account.

3.4 Provider fees and disclosure

In the course of Transfer Brokering or Levy Management engagements, training providers we recommend or coordinate with may pay LevySmart a fixed fee. This is disclosed to you in writing in the Engagement Letter for any engagement in which it applies. We do not accept undisclosed commissions, kickbacks, or referral arrangements that are not disclosed to the Client in advance.

4. Fees and payment

4.1 Fees

Fees for each engagement are set out in the Engagement Letter. Fees may be structured as:

  • A fixed fee for the engagement
  • A fixed fee per deliverable (for example, per audit or per transfer)
  • A monthly retainer for ongoing Management engagements
  • A combination of the above

We do not charge time-and-materials hourly rates as a default. Where a specific engagement is scoped in this way, it will be clearly stated in the Engagement Letter.

4.2 VAT

All fees are exclusive of VAT unless stated otherwise. VAT will be applied at the prevailing rate where applicable.

4.3 Expenses

Reasonable, pre-agreed expenses (such as long-distance travel) will be invoiced at cost with receipts provided. Expenses below £50 in aggregate per engagement are not separately invoiced.

4.4 Invoicing

We invoice in accordance with the schedule set out in the Engagement Letter. Typical patterns include:

  • 50% on engagement, 50% on delivery (for one-off engagements)
  • Monthly in advance (for retainers)
  • On completion of each milestone (for multi-stage engagements)

4.5 Payment terms

Invoices are payable within 30 days of the invoice date by bank transfer to the account specified on the invoice.

4.6 Late payment

If an invoice is not paid by its due date:

  • We may charge interest under the Late Payment of Commercial Debts (Interest) Act 1998 at the rate of 8% above the Bank of England base rate
  • We may suspend the Services on 7 days' written notice
  • We reserve the right to recover reasonable debt recovery costs in accordance with that Act

We will always contact you about an overdue invoice before taking any of the above steps.

5. Your responsibilities

To allow us to deliver the Services effectively, you agree to:

  • Provide accurate, complete, and timely information about your Apprenticeship Service Account and apprenticeship activity
  • Respond to reasonable requests for information or decisions within the timeframes we agree
  • Identify a single point of contact (usually in HR, finance, or L&D) authorised to make day-to-day decisions on your behalf
  • Make any decisions within your remit that are required for the Services to progress (such as approving a transfer or selecting a provider)
  • Notify us promptly of any material change in your circumstances that affects the engagement (a change in headcount, ownership, levy status, or strategic direction)

If we are delayed or prevented from delivering the Services because of a delay or omission on your part, we will not be liable for the delay and we may revise the timeline or fees accordingly.

6. Deliverables and intellectual property

6.1 Ownership of Deliverables

When you have paid all fees due for an engagement, you receive a perpetual, royalty-free, non-exclusive licence to use the Deliverables we provide to you for your own internal business purposes.

6.2 LevySmart's intellectual property

The following remain the property of LevySmart at all times and are not transferred to you:

  • Our methodologies, frameworks, templates, and analytical models
  • Anonymised, aggregated insights derived from the engagement
  • Any pre-existing materials we used in delivering the Services

You may not redistribute the Deliverables externally, publish them, or use them to create derivative works for sale.

6.3 Use of anonymised insights

We may use anonymised, aggregated information from engagements to improve our services, develop benchmarks, and inform our advisory work for other clients. We will not disclose information that identifies you, your organisation, or any individual at your organisation in any such use.

6.4 Reference and case studies

We will not name you publicly as a client, publish a case study about our work for you, or use your logo on our website or marketing materials without your prior written agreement.

7. Confidentiality

7.1 Mutual confidentiality

Each party agrees to keep confidential all non-public information disclosed by the other party in connection with the engagement, including:

  • Commercial information (strategy, financials, plans)
  • Technical information
  • Personal data (governed additionally by clause 8)
  • The terms of any Engagement Letter

7.2 Permitted disclosures

Confidentiality does not apply to information that:

  • Is or becomes public other than through breach of this clause
  • Was lawfully in the recipient's possession before disclosure
  • Is independently developed by the recipient
  • Is required to be disclosed by law, regulator, or court order — in which case the recipient will give the disclosing party reasonable notice where lawful to do so

7.3 Duration

Confidentiality obligations continue for 6 years after the engagement ends.

7.4 Permitted internal use

We may share Confidential Information internally with members of the LevySmart team and with our professional advisers (accountant, solicitor, insurer) who are themselves bound by confidentiality.

8. Data protection

8.1 Roles

Where we process personal data on your behalf in the course of the Services, you are the data controller and LevySmart acts as a data processor, in each case as defined in the UK GDPR.

8.2 Our obligations as processor

When acting as a processor on your behalf, we will:

  • Process personal data only on your documented instructions
  • Ensure that anyone we authorise to process the data is bound by appropriate confidentiality obligations
  • Implement appropriate technical and organisational security measures
  • Assist you in responding to data subject requests, where reasonably required
  • Notify you without undue delay if we become aware of a personal data breach affecting your data
  • Delete or return your personal data at the end of the engagement, as you choose, except where retention is required by law

8.3 Data Processing Agreement

We will, on your request, sign a Data Processing Agreement (DPA) recording the matters required by Article 28 of the UK GDPR, in either our standard form or a reasonable form provided by you.

8.4 Sub-processors

The sub-processors we currently use are listed in our Privacy Policy. We will inform you in advance of any addition or replacement of sub-processors who handle your personal data.

9. Liability

9.1 What we do not exclude

Nothing in these Terms limits or excludes liability for:

  • Death or personal injury caused by negligence
  • Fraud or fraudulent misrepresentation
  • Any other liability that cannot lawfully be excluded

9.2 Liability cap

Subject to clause 9.1, LevySmart's total liability to you in respect of an engagement (whether arising in contract, tort, breach of statutory duty, or otherwise) is capped at the total fees paid or payable by you for that engagement.

9.3 Indirect loss

Subject to clause 9.1, neither party is liable for indirect, consequential, or special losses, including loss of profits, loss of business, loss of anticipated savings, loss of goodwill, or loss of data, however arising.

9.4 Tax outcomes and HMRC

LevySmart provides advisory guidance based on published HMRC and Department for Education rules and guidance as understood at the time of the advice. We are not responsible for:

  • Subsequent changes to those rules
  • Decisions made by HMRC, the Department for Education, or the Apprenticeship Service that depart from published guidance
  • Outcomes that result from incomplete or inaccurate information you provide to us
  • Decisions you make to depart from our recommendations

We strongly recommend that any material decision affecting tax position or regulatory compliance is reviewed with your tax advisor or solicitor before action.

9.5 Insurance

LevySmart maintains professional indemnity insurance appropriate to the nature and scale of its business. Details are available on request.

10. Term and termination

10.1 Term

The engagement runs for the period set out in the Engagement Letter, or until the Services are completed, whichever is sooner.

10.2 Termination for convenience

Either party may terminate an engagement on 14 days' written notice to the other.

10.3 Immediate termination

Either party may terminate an engagement with immediate effect by written notice if the other party:

  • Commits a material breach of these Terms or the Engagement Letter and fails to remedy that breach within 14 days of being notified in writing, or
  • Becomes insolvent, enters administration or liquidation, or is unable to pay its debts as they fall due

10.4 Effect of termination

On termination of an engagement:

  • You will pay all fees due up to the termination date, including for work in progress at our reasonable assessment
  • We will deliver to you any Deliverables completed at the date of termination
  • Each party will return or destroy the other's Confidential Information, except where retention is required by law
  • Clauses that by their nature should survive termination (including confidentiality, IP, liability, and data protection) continue to apply

11. General

11.1 Notices

Any formal notice under these Terms must be in writing and sent to the relevant party at the address or email specified in the Engagement Letter.

11.2 Variation

No variation of these Terms is effective unless agreed in writing by both parties. An Engagement Letter signed by both parties constitutes such a variation for the engagement it covers.

11.3 No partnership

Nothing in these Terms creates a partnership, joint venture, agency, or employment relationship between us. Neither party may bind the other.

11.4 Assignment

You may not assign or transfer your rights under an engagement without our prior written consent. We may assign our rights to a successor entity in connection with the sale, restructuring, or transfer of our business, on giving you written notice.

11.5 Severability

If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions continue in full force and effect.

11.6 Force majeure

Neither party is liable for any failure or delay in performance caused by circumstances beyond its reasonable control, including (but not limited to) acts of God, governmental action, civil disturbance, or substantial failure of utilities or telecommunications. The affected party will notify the other promptly and use reasonable efforts to resume performance.

11.7 Entire agreement

These Terms, together with the relevant Engagement Letter, constitute the entire agreement between the parties in relation to the engagement and supersede any prior representations, understandings, or agreements.

11.8 Third-party rights

A person who is not a party to an engagement has no rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any term of these Terms.

12. Disputes and governing law

12.1 Talk first

If a dispute arises between us, we agree to attempt to resolve it through good-faith discussion before escalating. Either party may request a meeting of senior representatives to discuss the dispute, which will be held within 14 days of the request.

12.2 Mediation

If the dispute cannot be resolved through direct discussion, the parties agree to consider mediation through a recognised UK mediation service before commencing legal proceedings.

12.3 Governing law

These Terms and any engagement under them are governed by the laws of England and Wales.

12.4 Jurisdiction

The parties submit to the exclusive jurisdiction of the courts of England and Wales in relation to any dispute that cannot be resolved under clauses 12.1 or 12.2.