Data privacy and protection

Data Drives Insight Privacy Policy

Introduction:

DataDrivesInsight.com Pty Ltd (ABN 62 632 506 364) (“DDI”, “we”, “us” or “our”) is committed to protecting personal information and handling it responsibly.

This Privacy Policy explains how we collect, hold, use and disclose personal information in connection with our websites, technology platforms, assessments, surveys, learning programs and other products and services.

We handle personal information in accordance with the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs), where applicable.

Scope:

This Privacy Policy applies to personal information collected in connection with DDI’s products and services, including Team Excel, Leader Excel and other assessment, learning, leadership, team and organisational development products and services provided by DDI.

It applies to information relating to clients, prospective clients, employees of client organisations, assessment and survey participants, authorised users, accredited practitioners, partners, suppliers and other people who interact with DDI.

Some DDI products or services may use third-party platforms or administrators. Where this occurs, the relevant third party’s privacy policy and terms may also apply.

What Personal Information We Collect?

The types of personal information we collect depend on how you interact with DDI and which products or services you use.

This may include:

Identification and contact information, such as:

  • name;
  • email address;
  • mobile telephone number, where provided;
  • organisation;
  • team, department or business unit;
  • job title or role; and
  • other information reasonably required to administer the relevant product or service.

Assessment, survey and program information, such as:

  • responses to Pulse Checks, surveys and assessments;
  • feedback provided about or by participants;
  • team and organisational information;
  • learning and development activity;
  • assessment results and scores;
  • reports and analytics generated through our products and services; and
  • information provided through workshops, coaching or other DDI services where relevant.

Account and technical information, where applicable, such as:

  • account and login information;
  • records of access to and use of our platforms;
  • device, browser and technical information;
  • IP address; and
  • information required to maintain the security and operation of our systems.

Subscription and billing information, such as:

  • billing contact details;
  • subscription type and status;
  • transaction and payment status;
  • invoices and payment history;
  • discounts or promotional arrangements; and
  • other information required to administer a subscription or commercial relationship.

Payments may be made through a range of methods, including invoice, bank transfer or a third-party payment processor such as Stripe.

Where payments are processed by a third-party payment provider, DDI does not ordinarily receive or store complete payment card details.

We seek to collect only the personal information reasonably necessary for the products and services we provide.

How We Collect Personal Information?

We may collect personal information:

  • directly from you;
  • when you create or use an account;
  • when you complete an assessment, Pulse Check, survey or other activity;
  • when you communicate with us;
  • when you purchase or subscribe to a product or service;
  • from an organisation that engages DDI or uses one of our products or services;
  • from an authorised practitioner, consultant, partner or administrator;
  • through a third-party assessment or survey platform used to provide a DDI service; or
  • automatically through our websites or technology platforms where appropriate.

For workplace products such as Team Excel, a participating organisation may provide DDI with information about participants so that we can administer the program.

This may include names, email addresses, team information and optional mobile telephone numbers.

Participants may therefore receive an invitation to participate in a DDI product or service even where their contact information was initially provided to us by their employer or another participating organisation.

Mobile Numbers and SMS Communications

Where a mobile telephone number is provided in connection with Team Excel or another DDI service, we may use it to administer that service.

This may include sending SMS communications containing:

  • assessment or Pulse Check invitations;
  • secure links to participate;
  • reminders;
  • notifications relating to participation; and
  • other service-related communications.

Providing a mobile number for Team Excel is optional unless otherwise advised.

Where no mobile number is provided, participants may continue to receive relevant program communications through email or other available communication methods.

Mobile telephone numbers supplied for the administration of a DDI product or service will not automatically be used for unrelated marketing purposes.

Why We Collect and Use Personal Information

We collect, hold and use personal information where reasonably necessary to provide and operate our products and services.

This may include using information to:

  • establish and manage accounts;
  • administer assessments, Pulse Checks and surveys;
  • send invitations, links and reminders;
  • provide reports, analytics and feedback;
  • provide learning and development content;
  • support organisational, leadership and team development initiatives;
  • administer subscriptions, invoicing and payments;
  • provide technical and customer support;
  • communicate with clients, participants and authorised users;
  • maintain and improve our technology and services;
  • maintain security and prevent misuse;
  • undertake research, analysis and benchmarking using appropriately aggregated or de-identified information;
  • comply with legal and regulatory obligations; and
  • otherwise perform our contractual obligations to clients and users.

We do not use identifiable assessment or Pulse Check responses for unrelated marketing purposes.

Team Excel

Team Excel Pulse Checks are administered through DDI’s own technology platform.

DDI may receive participant information from the participating organisation, including names, email addresses, team information and, where provided, mobile telephone numbers.

This information is used to administer Team Excel, provide access, issue invitations and reminders, manage participation and provide appropriate support.

Individual Pulse Check responses are treated as confidential and are not ordinarily provided to participating organisations, team leaders, authorised users or registered partners in an individually identifiable form.

Results are generally reported on an aggregated basis and may be subject to minimum-response thresholds designed to protect participant confidentiality.

DDI may use aggregated, anonymised or de-identified Team Excel information for purposes including benchmarking, research, analytics, product development and improving Team Excel, where permitted by law.

Leader Excel and Third-Party Assessment Platforms

Some DDI products and services, including Leader Excel and other assessment products, may use a third-party assessment, survey or administration platform.

Depending on the product or service, providers may include platforms such as Leaderskill or Spidergap, or other providers selected by DDI from time to time.

Where a third-party platform is used, information necessary to administer the assessment or service may be provided to or collected directly by that provider.

This may include participant names, email addresses, assessment responses and other information required to administer and report on the relevant assessment.

The collection, storage, processing and handling of information by that provider may also be governed by the provider’s own privacy policy, terms and conditions.

DDI selects third-party providers having regard to factors including their privacy, security and data-handling practices.

Participants should review any applicable third-party privacy policy or terms made available when using those services.

Confidentiality of Assessments and Survey Responses

DDI recognises that assessments and workplace surveys may involve confidential or sensitive information.

We take reasonable steps to ensure that assessment and survey information is accessed and disclosed only for appropriate purposes.

How results are reported depends on the particular product.

Some products, such as Team Excel, primarily report aggregated team or organisational results.

Other products, including individual leadership or 360-degree assessments, may generate individual reports or feedback intended for a particular participant, coach, facilitator or authorised organisational representative.

The applicable assessment process will determine how those results are provided and who is authorised to receive them.

Payments and Billing

DDI may accept payment through a range of methods, including electronic payment through a third-party payment processor such as Stripe, or by invoice and bank transfer.

Where a third-party payment processor such as Stripe is used, that provider may collect and process payment information and other personal information necessary to process transactions, manage recurring payments, prevent fraud and provide payment services.

DDI may receive and retain billing and transaction information such as the customer’s name, organisation, billing contact details, subscription or service purchased, amount payable or paid, payment status, invoice details and transaction reference.

DDI does not ordinarily receive or store complete payment card details where payments are processed by a third-party payment provider.

Where payment is made by invoice or bank transfer, DDI may collect and retain information reasonably necessary to issue the invoice, reconcile the payment and maintain appropriate financial and accounting records.

Information processed by a third-party payment provider is also subject to that provider’s own privacy practices and terms.

Service Providers

DDI uses third-party service providers to help operate and deliver our products and services.

These may include providers of:

  • cloud hosting and data storage;
  • payment processing;
  • email and SMS communications;
  • authentication and account management;
  • assessment and survey administration;
  • learning management systems;
  • analytics;
  • customer relationship management;
  • technical support; and
  • other technology and professional services.

We seek to use reputable providers and take reasonable steps to assess appropriate privacy and security practices where those providers handle personal information on our behalf.

We disclose only the information reasonably necessary for those providers to perform their functions.

Data Storage and Security

DDI takes reasonable technical, organisational and administrative measures to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure.

DDI’s core technology infrastructure uses enterprise-grade cloud services, including Microsoft Azure.

Security measures may include, where appropriate:

  • encryption of data in transit;
  • access controls;
  • Multi-Factor Authentication;
  • role-based access;
  • secure cloud infrastructure;
  • monitoring and security controls; and
  • restrictions on access to personal and confidential information.

No technology system can guarantee absolute security.

If we become aware of a data breach involving personal information, we will assess and respond to it in accordance with applicable legal requirements.

Disclosure of Personal Information

DDI may disclose personal information where reasonably necessary to:

  • provide the product or service for which the information was collected;
  • administer an assessment or survey;
  • provide authorised reports, feedback or analytics;
  • process payments;
  • operate and support our technology;
  • engage authorised practitioners, partners or service providers;
  • comply with a legal obligation; or
  • protect the rights, safety or security of DDI, our users or others.

We do not sell personal information.

Where information was collected for a particular purpose, we will not ordinarily use or disclose it for an unrelated purpose unless permitted or required by law or with appropriate consent.

Overseas Processing and Disclosure

DDI aims to operate its core data platform and store data in an appropriate location having regard to the relevant client, product and service.

However, some of our service providers or third-party assessment platforms may process or store personal information outside Australia.

The location of processing may depend on the particular service provider, product and client arrangement.

Where personal information is disclosed to an overseas recipient, DDI will take reasonable steps to handle the disclosure in accordance with applicable Australian privacy requirements.

Where practicable, information about the countries in which relevant third-party providers process or store personal information will be made available through the relevant product, service documentation or provider privacy information.

Aggregated and De-identified Information

DDI may aggregate, anonymise or de-identify information so that it is no longer reasonably identifiable as relating to an individual.

We may use such information for purposes including:

  • research;
  • benchmarking;
  • analytics;
  • development of industry insights;
  • improving our products and services;
  • developing new products and features; and
  • understanding workplace, team and leadership trends.

Where information has been appropriately de-identified so that it is no longer personal information, DDI may retain and use that information for these purposes.

Data Retention

DDI retains personal information only for as long as reasonably necessary for the purposes for which it was collected, to provide our products and services, meet contractual requirements, maintain appropriate business records and comply with legal obligations.

Retention periods may vary depending on the type of information, product or service and applicable client arrangements.

When personal information is no longer reasonably required, we will take reasonable steps to delete, destroy or de-identify it where appropriate and subject to legal and technical requirements.

De-identified or aggregated information may be retained for research, benchmarking, analytics and product development purposes.

Accessing and Correcting Your Personal Information

You may request access to personal information DDI holds about you or ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading.

Requests can be made by contacting DDI using the details below.

We may need to verify your identity before providing access or making a correction.

There may be circumstances in which we are permitted or required by law to refuse access. If this occurs, we will explain the reason where required. 

Where information is held directly by a third-party assessment provider

You may contact DDI to request deletion of personal information we hold about you.

We will consider requests in accordance with applicable privacy laws, contractual requirements and legitimate record-keeping obligations.

There may be circumstances where we need to retain particular information, including to comply with legal requirements, maintain necessary business records, resolve disputes or protect legal rights.

Where information can appropriately be deleted or de-identified, we will take reasonable steps to do so.

Marketing Communications

DDI may communicate with clients, prospective clients, partners and other business contacts about products, services, events or information we believe may be relevant to them, where permitted by law.

Recipients may opt out of marketing communications using the unsubscribe mechanism provided or by contacting us.

Contact information supplied solely to enable an employee or participant to participate in an assessment, Pulse Check or other workplace program will not automatically be used for unrelated direct marketing.

Service communications necessary to administer an active product or service are separate from marketing communications.

Websites, Cookies and Analytics

Our websites and technology platforms may use cookies and similar technologies to operate our services, remember preferences, understand how our websites and platforms are used, improve functionality and maintain security.

We may also use analytics or advertising technologies where appropriate.

Where third-party analytics, advertising or tracking technologies collect personal information, we will seek to provide appropriate notice and manage those technologies in accordance with applicable privacy requirements.

Third-Party Websites and Services

Our websites, platforms or communications may contain links to websites or services operated by third parties.

DDI is not responsible for the privacy practices of independently operated third-party websites or services.

Where a third-party service forms part of a DDI product, such as an assessment platform or payment provider, the third party’s own privacy policy and terms may also apply.

We encourage users to review the relevant privacy information before providing personal information to an external service.

Privacy Complaints

If you have a concern or complaint about how DDI has handled your personal information, please contact us using the details below.

We will seek to acknowledge and investigate privacy complaints within a reasonable timeframe and work with you to resolve the matter.

If you are not satisfied with our response, you may be entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC).

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our products, technology, service providers, legal requirements or information-handling practices.

The latest version will be published on our website and will show the date it was last updated.

Where a change materially affects how we handle personal information, we may provide additional notice where appropriate.

You have the right to access, update, or request deletion of your personal information in accordance with the Australian Privacy Principles (principles 12 and 13). Requests can be made by contacting DDI directly at info@datadrivesinsight.com.au

Complaints

If you become aware of or have concerns regarding compliance with this policy, you are encouraged to raise this with DDI directly via info@datadrivesinsight.com.au. We are committed resolve such concerns as a matter of priority to the satisfaction of all parties.

If you are not satisfied that we can resolve your complaint, you can raise your concern with the Office of the Australian Information Commissioner:

Online: www.oaic.gov.au/privacy
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Mail: GPO Box 5218 Sydney NSW 2001