Personal Data Policy for 360° Feedback

What information do we hold?

• Names and email addresses supplied by our clients and by feedback participants
• Feedback responses supplied by feedback providers:
  • Performance scores
  • Free-text remarks about a person's performance

How do we obtain it?

We aim to process personal data for lawful purposes:

• Participants are identified by the client organisation for whom we are providing the 360° feedback service.
• Participants agree to use of the data when they log on to the system

What do we do with the personal data?

• Emails to participants in connection with the 360° feedback process
• Collation of feedback into 360° feedback reports. These are sent, by secure means, to:
  • The participants themselves - reports are usually issued as password-protected PDF files.
  • No further copies will be issued except as described elsewhere in this document or as notified to you by other means.
• Collation of feedback into higher-level reporting which does not identify individuals. These are sent to:
  • Designated people in the client organisation and external consultants working for the client organisation.
  • We may supply detailed data to the client for further analysis, for instance by using Excel pivot tables. Where this is done we first anonymise the data removing names, id numbers and remarks. We also ensure that individuals can't be identified by other attributes, such as department or grade.
• Progress reports to the client organisation which disclose the number of responses but not the detail of the feedback.
• Data is not passed on to 3rd parties
• Data is not used for automated decision-making

360° feedback reports

The 360° feedback service is intended to enable feedback providers to give their feedback anonymously so, in general:

• We don't disclose to feedback recipients the names of those who have or have not responded.
• We don't permit feedback recipients to "drill-in" to the data in a way which might single out individual feedback providers.
• These reports do not attribute feedback to specific individuals.
• Steps are taken to ensure that individual responses are consolidated with others to prevent identification of individuals.
• The exception to the above is feedback given by managers which is usually shown separately. (In sensitive situations their feedback their feedback can also be consolidated with that of other feedback providers.)
• Remarks, supplied as feedback, are printed verbatim, as received, but are not attributed.

Subject access requests

We will supply personal data to the relevant individual as part of a subject access request under the Data Protection Act. In the case of 360° feedback this would not provide a way for an individual to gain greater access to the data than as described above. For instance, we will to provide that data in a way that does not identify other individuals. Essentially the information disclosed would be equivalent to:

• a list of a feedback recipient's nominated feedback providers (but not whether they responded)
• a feedback recipient's original feedback report
• or a feedback provider's questionnaire response.

Retention

• Contact information is retained for the duration of the relationship with the client
• Feedback responses are removed after 2 years

Responsibilities

• Data Controller: Matlock Business Solutions Ltd
• Data Processor: Matlock Business Solutions Ltd

General Policy on Personal Data

• Data is held securely
• The types of data held and the purposes for which it is used are described on the relevant page for each application
• Data is retained within the EU
• Data is not passed to other parties except as described on the relevant page for each application
• We will respond promptly to requests to correct information
• We will respond promptly to subject access requests
• We will remove personal data from our systems ahead of the normal data period on request of the individual
• We will not use any data for automated decision-making

Contact

Subject access requests and requests for correction or removal of data should be addressed to:

• support@feedback-360.com

Contact and Other Information