Privacy Policy

Who this covers

This Privacy Policy describes how the ProventusHR Journey Portal ("the Portal") collects, uses, and protects personal data belonging to participants, managers, HR SPOCs, coaches, and administrators using the Portal as part of a ProventusHR leadership development programme.

What we collect, and why

• Account and profile data — your name, email, and role, used to identify you and control what you can access.
• Assessment responses — 360-degree rater feedback, Leadership Growth Progress Survey (LGPS) check-in responses, and self-assessment responses (such as the Relationship Styles Inventory), collected to generate your development reports and, where applicable, feedback about others you have been asked to rate.
• Programme activity data — attendance records, workshop feedback, leadership goals, individual development plan (IDP) entries, and gamification progress, used to run and track your programme journey.
• Coaching data — coach assignments and individual coaching session bookings, used to coordinate coaching support where your programme includes it.
• Meeting scheduling data — where a programme session is created with an online meeting link, limited data (names, email addresses, session time) is shared with the meeting provider used for that session, solely to generate the meeting.

How your data is protected

Sensitive free-text responses (rater open-ended comments and 360 debrief report narrative content) are encrypted at rest using AWS Key Management Service (KMS). Access to Portal data is enforced at the database level using row-level security, so a user can only ever retrieve the data their role and relationship to a record genuinely permit — not merely restricted by the application's own screens.

Your rights, and how we handle them

In line with India's Digital Personal Data Protection Act (DPDP), you may request a copy of the personal data we hold about you, or request that your identifying data be removed. When you make an erasure request, your name and email are irreversibly anonymized across every record in the Portal — the underlying programme records (such as aggregate assessment data that other participants' own reports may depend on) are retained in anonymized, non-identifying form rather than deleted outright, so that other people's legitimate records remain accurate and complete. Once anonymized, a record can never be re-linked back to you.

To exercise either right, contact your ProventusHR programme administrator.

Who we share data with

We share the minimum data necessary with the following third parties, solely to operate the Portal:

• Resend — sends transactional emails on our behalf (invitations, reminders, report-ready notifications). Resend receives only the recipient's email address and the email content itself.
• Zoom, Microsoft Teams, and Google Meet — when a programme session or coaching booking includes an online meeting, the relevant provider receives the meeting time and participant contact details needed to create that meeting, via that provider's own secure application credentials.
• Calendly — used for individual coaching session scheduling where your programme includes it; booking details are received via a secure webhook.

We do not sell personal data to any third party.

Data retention

Your data is retained for the duration of your programme and for a reasonable period afterward to support your own access to past reports and development history, unless you request erasure sooner as described above.

Contact

Questions about this policy or your data should be directed to your ProventusHR programme administrator.