This Privacy Statement pertains to Interpersonal Solutions Group Pty. Ltd. and its trading companies Culture Capital and ONA Solutions (together “The Companies”). The Companies are committed to respecting your privacy. This Privacy Statement sets out our practices regarding the collection, use, transfer and storage of personal information and survey data we collect.

The Companies adhere to the National Privacy Principles of the Australian Privacy Act and the European Commission’s General Data Protection Regulations (EU) 2016/679 Directive on Data Protection. This Privacy Statement may be updated from time to time to reflect new uses, regulations or technologies that impact your privacy.

The Companies provide individual, leadership, team, and organisation assessments to members of client companies and organisations. Persons undergoing individual or leadership assessments (‘Focal Leaders/Individuals’) may invite others (‘Raters’) to provide feedback as part of the assessment process. Assessments are generally administered online through the Interpersonal Solutions Group Pty. Ltd. assessment platform (The Development Platform).

Collection, Use, and Disclosure

For individual and leadership assessments such as the CLS360, CBS360, and HPS360, the Companies collect information from Focal Leaders/Individuals and Raters to provide Focal Leaders/Individuals with feedback on their leadership, personality, and interpersonal behaviour for the agreed upon purposes. The client organisation undertakes, where applicable, to obtain the permission of the participant/coachee for the reporting of the results if these go beyond developmental purposes (e.g., administrative purposes such as selection or promotion decisions).  The Companies reserve the right to obtain proof of such permission before reporting to the client and to inform the Focal Leaders/Individuals that they will be reporting the results to the client.

Feedback reports are debriefed by a coach or certified consultant; no automated decisions are made on the basis of the data or reports. Feedback reports are provided only to the Focal Leader/Individual and his/her coach or certified consultant unless the Focal Leader/Individual actively consented to further sharing. Raters are informed that the Focal Leader/Individual they are rating may choose to share his/her results with others.

For team and organisation assessments such as the Circumplex Culture Scan™ (CCS) and Circumplex Team Scan™ (CTS), the Companies collect information from team and organisation members to promote team and organisational development. Results are debriefed by a certified consultant; no automated decisions are made on the basis of the data or results. Results are provided to the certified consultant, team member respondents, and persons designated by the client organisation such as human resource practitioners and project sponsors.

If minors wish to complete any assessments provided by the Companies, permission of the minor’s parents or legal representatives will be obtained.

The information we collect is treated confidentially and will not be used for marketing or divulged to third parties. However, responses we collect to our assessments may be used for scientific research in the social sciences and presentation of group data.

For project management purposes, such as assessment administration or registration for online access, we may receive personal information about Focal Leaders/Individuals, Raters, and team and organisation members from the client organisation. This information is usually limited to name, business email address, and general job information (for example, department or location).

Data Quality and Data Security

The Companies use their best efforts to ensure the personal information they collect and use in the course of and for the purpose of administering assessments and reports is accurate, complete, and up-to-date. We take precautions to protect personal information we collect both online and offline. Online information is stored on servers in locked, secure environments. These servers are protected from unauthorised intrusion with firewalls and a variety of other security mechanisms and procedures. The personal information we collect, and store is treated as confidential information and is only accessible by our employees or contractors who perform specific functions related to the assessments or by designated client organisation administrators.

Access and Correction

Focal Leaders/Individuals, Raters, and team and organisation members can review and edit their own online Client Account information, which includes name, password and e-mail address. During the survey process, they may return to the survey platform to update their own survey responses until they complete and submit their survey in full, or reports are produced.

After the survey process is complete, Focal Leaders/Individuals and Raters, and team and organisation members have access to their own survey responses upon written request if the data are still maintained by the Companies and has not been destroyed. No individual will be allowed to access or review another individual’s data. If access is desired, contact the Companies using the contact information provided in this Privacy Statement (see Enforcement and Contact Information).

Data Storage and the Right to Erasure

The Companies may keep the data it collects for 30 years. Data for (social) scientific research may be kept indefinitely. Focal Leaders/Individuals can receive a copy of the data we keep of you upon simple request (See Enforcement and Contact Information).

The ‘right to erasure’ (i.e., the right to have one’s personal data erased) may be exercised at any time after the survey process is complete by clicking here.

Anonymity

Raters who are completing an individual or leadership survey at the request of a Focal Leader/Individual will be clearly notified at the beginning of the survey whether they have the option to complete that survey anonymously or not. If anonymity is an option, it requires active selection by the Rater.

By choosing to remain anonymous, the Rater’s feedback will not be identifiable to the Focal Leader/Individual, but instead will be grouped (averaged in) with other Rater data or presented anonymously in a randomised manner along with at least two other  anonymous Raters’ feedback. A single, anonymous Rater’s feedback will not be presented. If anonymity is not an option, the Rater will be instructed at the beginning of the survey to actively consent to providing identifiable feedback or to exit the survey. If the Rater does not actively consent to having his/her feedback identified, he/she cannot access the survey. In that case, the Rater will not participate in the survey feedback process.

Due to the nature and purpose of the assessment services we provide, Focal Leaders/Individuals must be identifiable to receive a Focal Leader/Individual feedback report. If the Focal Leader/Individual wishes to remain anonymous, he or she is not able to complete the survey and receive a feedback report.

For team and organisation assessments such as the Circumplex Culture Scan™ (CCS) and Circumplex Team Scan™ (CTS), responses are anonymous because individual responses are aggregated with the responses of at least two other individuals in the team or organisation when results are presented. The names of the individual respondents who completed the assessments about their team or organization may be listed in the results report or placed on an organisational network map.

Trans-border Data Flow

The assessment data we collect are processed in Australia and may be transferred outside of Australia in a secure, encrypted format, for purposes of report processing or scientific research. Whenever possible, personal information, other than survey responses, will be removed from such data. The Companies take reasonable steps to ensure that the information which is transferred is treated by the recipient in a manner consistent with Australia’s National Privacy Principles and the EU General Data Protection Regulations. A notice of such possible transfer is clearly visible on the survey website upon login. If Focal Leaders/Individuals or Raters, or team and organisation members do not wish to consent to such possible transfer of data, they should not complete the survey.

Enforcement and Contact Information

Questions or concerns regarding the use or disclosure of personal information should be directed to:

Interpersonal Solutions Group Pty. Ltd Attention: Mr. Quentin Jones
Address: GPO Box 3273
Address: Melbourne, Victoria, Australia, 3001
Telephone: +61 3 9787 2520
Email: quentin@interpersonalsolutionsgroup.com

The Companies will investigate and endeavour to resolve complaints and disputes regarding the use and disclosure of personal information in accordance with the principles contained in this Privacy Statement.

Notification of Changes

Any changes to our privacy policy will be posted to this Privacy Statement on our homepage and other locations we deem appropriate. We will treat information in accordance with the privacy policy that was current at the time the information was collected.

Updated: March 2018