PRIVACY POLICY

Empathia Group Pty Ltd

We respect your privacy

Empathia Group Pty Ltd respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). This policy sets out how we collect and treat your personal information.

“Personal information” is information we hold which is identifiable as being about you.

Collection of personal information

Empathia Group Pty Ltd will, from time to time, receive and store personal information you enter onto our website, provided to us directly, enter into our employee survey as instructed by your employer or given to us in other forms.

You may provide basic information such as your name, phone number, address and email address to enable us to send information, provide updates and process your product or service order. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.

Additionally, we may also collect any other information you provide while interacting with us.

How we collect your personal information

Empathia Group Pty Ltd collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website, when you complete our employee survey services as instructed by your employer, you complete a self-assessment and when we provide our services to you. We may receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy.

Personal data we collect

In our capacity as a data processor, we will collect and process the following personal data about you as instructed by your employer.

Information you give us. 

You may give us information about you: when using the employee survey or self-assessment systems, including by filling in forms, providing individual feedback or completing surveys on or via the system. The extent of the information collected in surveys is set by your employer. This information may include your name, age, company email address, company telephone number, job title, level of seniority, department, work start date, salary and primary office location, as well as any views/comments you provide to us about you or your colleagues’ performance in your respective roles, or information regarding your employer, your colleagues or other third parties during the course of completing surveys or otherwise using the system.

Information your employer gives us. 

Your employer may give us information about you: when the employee survey is being created in order to enable you to access the system under the Terms of Business (whether on a trial or full basis) or to enable us to send surveys, individual feedback requests and similar communications to you. This information may include your name, age, company email address, company telephone number, job title, level of seniority, department, work start date, salary and primary office location. We may obtain further information about you from your employer, for example to verify your eligibility to access and use the system.

Information we collect about you. 

Each time you complete a survey we may automatically collect the following information: when you use the system, we will keep a record of the details of that usage, including the date, time, location, frequency and duration of the usage; technical information about your computer or mobile device for system administration and analysis, including your IP address, URL clickstreams, unique device identifiers, operating system, and network and browser type.

Use of your personal information.

Empathia Group Pty Ltd may use personal information collected from you to   provide you with information, updates and our services. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information to improve our products and services and to better understand your needs.

Empathia Group Pty Ltd may contact you by a variety of measures including, but not limited to telephone, email, sms or mail.

Where we have collected, received or generated personal data from or about you, we may use this for the purposes set out below: 

carry out our obligations arising from the Terms of Business. This includes providing your employer with aggregated and de-identified reports and analysis summarising information provided during your use of the system, including in any engagement surveys, aggregated with information from other employees and personnel, and (where relevant) comparing this data with past or future employee responses and/or industry benchmarks. Where applicable, this will also include providing you with individual feedback comments from your colleagues, and providing your individual feedback to your colleagues. All survey and/or individual feedback responses are entirely optional: individual questions (or the entire survey) may be skipped and there is no requirement for any surveys to be completed;

deal with any enquiries, correspondence, concerns or complaints you have raised, or that have been raised by or concerning third parties (such as your employer) involving you and any issues caused by your use of the system.

Information we collect about you.

We will use this information:

to report to your employer relating to the use of the system, as may be required under the Terms of Business;

In relation to the above uses, we shall process your personal data on the legal basis determined by your employer, including to enable us to perform our contractual obligations under the Terms of Business.

Our surveys will not request any special categories of personal data (including racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, sex life or sexual orientation), unless this has been expressly requested or configured by your employer. Where this is the case, it is your employer’s responsibility to ensure they have obtained your explicit consent to such processing or that they have another lawful basis for such processing (please contact your employer if you have any questions). However, you might, in the course of providing comments or feedback in a survey, provide personal data within one of the above categories where this has not been requested.

Data collected from you and other employees or personnel may be used by us in an aggregated and de- identified form for statistical and benchmarking purposes including enabling comparisons to other organisations within the same industry.

Disclosure of your personal information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy.  Personal information is only supplied to a third party when it is required for the delivery of our services.

We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.

We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Empathia Group Pty Ltd, www.empathiagroup.com/www.empathiagroup.com.au, its customers or third parties.

Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia.

If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.

Engagement survey: responses and your employer 

Please note that:

feedback and comments provided by you during engagement surveys are collated and conveyed to your employer in an aggregated or de-identified form. As such, your identity is protected by default. Please also note that we merely report the feedback and comments and do not undertake any investigation or assessment into their veracity or legality;

the system may include an automated keyword flagging function, using a list of keywords which are pre- agreed by your employer. Any word in comments contained in an engagement survey which matches a keyword is automatically reported to your employer, without revealing your identity. We do not, however, notify you when any keywords originating from you are reported to your employer. This keyword flagging

function operates automatically and we do not carry out any manual checks or otherwise monitor, supervise or exercise any discretion over the transmission of keywords to your employer.

Engagement survey: Who can see your survey responses within your organization

The system’s access controls and data visibility settings provide your employer with the ability to protect your identity and restrict who can see your survey responses. We believe these configurations provide the essential controls to your employer to ensure everyone is heard on equal footing and to ensure you feel comfortable raising the issues you feel strongly about.

Individual feedback responses Please note that:

Comments you provide in response to surveys are visible to your manager and other applicable persons determined by your employer, e.g. your line manager and/or any designated mentor(s). To protect your privacy, comments are not shown with any identifying information. Unless you write something in your comment that makes it obvious who you are (e.g. include your name or other information that may reveal your identity in the free text field), your manager will not know who wrote the comment when they read it. Likewise, if your manager responds to a comment through the system, you can respond back knowing that your manager does not know whom they are conversing with.

To protect your privacy, we also take steps to aggregate the scores you give with scores given by other employees so your identity cannot be deduced. The level of aggregation is specified by your employer. That means your individual scores are not shown to your manager. You can see more details about how your data is processed on the survey start page (before you start answering questions).

Except as explained above, we will not disclose your personal data to any third parties for any other purpose unless we have a legal right or obligation to do so.

Security of your personal information

Empathia Group Pty Ltd is committed to ensuring that the information you provide   to us is secure. In order to prevent unauthorised access or  disclosure, we have   put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Access to your personal information

You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth). A small administrative fee may be payable for the provision of information. If you would like a copy of the information, which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at [email protected].

We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.

Complaints about privacy

If you have any complaints about our privacy practices, please feel free to send in details of your complaints to 24 Discovery Drive, Fletcher, New South Wales, 2287. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

Changes to Privacy Policy

Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.

Website

When you visit our website

When you come to our website (www.empathiagroup.com/www.empathiagroup.com.au) we may collect certain information such as browser type, operating system, website visited immediately before coming to our  site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

Cookies

We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads    to website visitors through third party services such  as  Google Adwords.  These ads may appear on this website or other websites you visit.

Third party sites

Our site may from time to time have links to other websites not owned or   controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Empathia Group Pty Ltd is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

Approved by

Full Name: John Harries

Date: 24th November 2021