Privacy and data protection policy
1. Introduction
This Privacy Policy explains how Untapped ("we," "us," "our") processes personal data through our WayPoint portal, a platform designed to connect neurodivergent individuals with employment and skill development opportunities. We are committed to protecting your privacy and handling your data transparently and responsibly in compliance with the General Data Protection Regulation (GDPR).
2. Data Controller Information
To ensure transparency and accountability in how your data is handled, we want you to know who is legally responsible for protecting your information.
Untapped serves as the data controller for personal information processed through WayPoint. Our Data Protection Officer can be contacted at: privacy@untapped-talent.com
3. Categories of Personal Data We Process
To provide our employment support and matching services effectively, we need to collect several types of personal information about you.
We collect and process the following categories of personal data:
Essential Personal Information
- Full name and contact details
- Date of birth
- Contact preferences
- Emergency contact information
Professional Information
- Education history
- Employment history
- Skills and qualifications
- Professional certifications
- Work availability and preferences
Support-Related Information
- Neurodivergent status and related accommodations needed
- Support preferences and requirements
- Meeting notes from support consultant sessions
- Progress tracking information
- Psychometric test results and profiles
- Any relevant medical or allied health reports, such as a sensory profile
Platform Usage Data
- Login information and activity logs
- Communication preferences
- Platform interaction history
4. Purposes and Legal Basis for Processing
Understanding why we process your data and our legal right to do so is fundamental to maintaining trust and transparency in our relationship. We’ve outlined these purposes below.
Career Development and Support (Legal basis: Contract & Consent)
- Matching candidates with suitable employment opportunities
- Providing personalized support through assigned consultants
- Tracking progress in skill development programs
- Facilitating workplace accommodations
Program Administration (Legal basis: Legitimate Interests)
- Managing the enrolment process
- Coordinating with partner organizations
- Maintaining program records
- Quality assurance and service improvement
Communication (Legal basis: Consent & Legitimate Interests)
- Sending program updates and notifications
- Scheduling support sessions
- Facilitating communication between candidates and employers
- Providing educational resources
5. Data Processing Methods
We use a combination of secure digital and manual methods to handle your personal information in ways that protect your privacy while delivering our services effectively.
We process your data through:
- Secure online platform operations
- Encrypted database storage
- Manual processing by authorized support consultants
- Automated matching algorithms for employment opportunities
6. Data Retention
We keep your personal information only for as long as necessary to provide our services and comply with legal requirements.
We retain your personal data for:
- The duration of your active participation in our programs
- Up to 2 years after program completion for follow-up support
- Up to 7 years for certain data required by employment law
- Specific retention periods are reviewed and updated based on legal requirements and business needs
7. Your Rights Under GDPR
The GDPR provides you with important rights over your personal data, and we are committed to helping you understand and exercise these rights.
You have the right to:
- Access your personal data
- Correct inaccurate personal data
- Request erasure of your personal data
- Restrict or object to processing
- Data portability
- Withdraw consent at any time
- Lodge a complaint with a supervisory authority
8. Data Sharing and Recipients
To provide our comprehensive support services, we sometimes need to share your information with trusted partners and service providers.
We may share your data with:
- Authorized support consultants
- Partner employers (with your explicit consent)
- Third-party service providers who assist in platform operation
- Regulatory authorities when legally required
9. Data Security
Protecting your personal information is our top priority, and we implement robust security measures to keep your data safe.
We implement appropriate technical and organizational measures to ensure data security, including:
- Encryption of personal data
- Regular security assessments
- Staff training on data protection
- Access controls and authentication measures
- Regular backup procedures
Compliance with ISO27001 has been achieved and externally audited.
10. International Data Transfers
Personal data collected through WayPoint may be transferred to Australia, where our parent company Untapped is located. When transferring your personal data to Australia, we ensure appropriate safeguards are in place to protect your privacy rights:
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We rely on the European Commission's adequacy decision for transfers to Australian organizations that are subject to the Privacy Act 1988
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We implement Standard Contractual Clauses (SCCs) approved by the European Commission
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We maintain strict internal data protection policies governing how your data is handled
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We ensure that all data transfers comply with applicable data protection laws
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We implement additional technical and organizational measures to protect data during transfer and processing
You can request a copy of the safeguards we use for international transfers by contacting our Data Protection Officer.
11. Changes to This Privacy Policy
We may update this Privacy Policy periodically. Significant changes will be communicated through the WayPoint portal and, where appropriate, via email.
12. Contact Information
For any questions about this Privacy Policy or to exercise your rights, please contact:
13. Special Considerations for Neurodivergent Users
We understand that processing complex information can be challenging. If you need this Privacy Policy explained in a different format or require assistance understanding your rights, please contact our support team who can provide:
- Simplified explanations
- Visual formats
- One-on-one guidance sessions
- Alternative communication methods
Last Updated: 12 December 2024