Privacy and Consent Policy v1.2
CultureQ is committed to responsible data stewardship and providing safe ways for people to speak up. This policy sets out how we collect, handle, protect, and dispose of personal information in the course of delivering organisational interviews, surveys, focus groups and associated analytics. This includes handling data we collect, and data or reports provided to us as part of our work. Our practices align with the Australian Privacy Principles (APPs). Its application is informed by the ethical obligations of the Australian Psychological Society (APS) Code of Ethics. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/.
Purpose
This policy applies to all organisational interview, focus group and survey programs we conduct or support on behalf of client organisations.
Data We Collect
We collect/receive the following categories of information for the purpose of conducting, reporting and acting on organisational interview, focus group and survey:
- Quantitative responses (ratings and scaled items reflecting employee opinion)
- Qualitative free-text responses,
- General demographic descriptors, such as gender, tenure, employment type, and organisational unit
Sensitive Information
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:
- For the primary purpose for which it was obtained
- For a secondary purpose that is directly related to the primary purpose
- With your consent; or where required or authorised by law.
Third Parties
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties, such as your employer or service provider. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Consent
Participation in interview, focus group and survey we administer or is administered by partner organisations should be voluntary. Before taking part, each participant receives a plain-language statement explaining the purpose of the survey, how their data will be used, and the anonymity protections in place, or absence there of. Proceeding with the program constitutes explicit, informed consent.
Withdrawal: Participants may withdraw at any time prior to reporting. To request exclusion or amendment of data already submitted, individuals should contact us directly. Given the anonymised and de-identified nature used in much of our work, we may not always be able to locate records attributable to a specific individual; however, we will make all reasonable efforts to assist. We will remove or amend the relevant records to the extent this is technically feasible.
Use of Information
Survey data primary purpose is to report back aggregated feedback and analysis to the client organisation. Interview data purpose can be to report back individual or aggregated feedback. Data may also be used to support follow-on work and provide aggregated benchmarking. With explicit client permission, aggregated data may be used for case studies.
Participant contact details will only be used to respond to enquiries or delivering project communications.
Data is never sold or exchanged with third parties.
Anonymity and Its Limits
Interviews
Where anonymity is provided, feedback will be de-identified. We apply a minimum respondent threshold to all reported demographics or groupings to prevent indirect identification. Participants should be aware that open-ended responses may carry a higher risk of inadvertent identification, particularly where responses contain specific anecdotes, references to events, or descriptions that could be attributed to a known individual. We encourage participants to disclose generalisations and broad observations to avoid content that could identify themselves or others.
We reserve the right to disclose information without consent only in the rare and exceptional circumstance where disclosure is required by law or where there is a credible risk to the life, health, or safety of an individual.
Staff Surveys / Focus Groups
Results are reported only in aggregate form. To protect individual anonymity, we apply a minimum respondent threshold to all reported groupings; where the number of respondents in a subgroup falls below this threshold, results for that subgroup are suppressed rather than disclosed.
Participants should be aware that open-response questions may carry a higher risk of inadvertent identification, particularly where responses contain specific anecdotes, references to events, or descriptions that could be attributed to a known individual. We encourage participants to write in general terms and to avoid content that could identify themselves or others.
We reserve the right to disclose information without consent only in the rare and exceptional circumstance where disclosure is required by law or where there is a credible risk to the life, health, or safety of an individual.
Data Security and Storage
All interview, focus group and survey data and reports are stored within Australia. All data is encrypted in transit and at rest. All CultureQ staff who work with people data are bound by confidentiality obligations as a condition of their engagement.
Microsoft SharePoint serves as our enterprise-grade cloud infrastructure. Microsoft enforces industry-leading security practices, including 24/7 physical data centre monitoring, real-time threat detection, and proactive platform patching managed by dedicated security professionals. This underlying infrastructure meets a comprehensive set of international and Australian-specific compliance standards, including ISO 27001, SOC 1 and SOC 2, and is assessed under the Australian IRAP (Information Security Registered Assessors Program) to the PROTECTED level. This ensures a secure, high-availability foundation that protects your data.
Data Retention and De-identification
Where surveys, focus groups or interviews are conducted anonymously, no personal information is paired with feedback and responses cannot be traced to individuals.
Where data contains identifiable response data, data is retained for 36 months following the final wave, after which it is de-identified. Client organisations may request earlier de-identification and, where practicable, fulfilled within a reasonable timeframe.
Privacy Policy Complaints and Enquiries
For more information, please contact your organisations internal project contact.
For privacy-related enquiries, consent withdrawal requests, please reach out to Contact@CultureQ.com.au
Complaints are owned by a Director, acknowledged within [5] business days and responded to within 30 days.