Privacy notice

CultureLens Circles is provided by IV Talent, a company headquartered in South Carolina, USA. It is used inside a team, usually at the request of the organisation that team belongs to. In most cases that organisation decides why the tool is used and what happens to the information in it, and IV Talent handles the information on its behalf. IV Talent also holds a small amount of information in its own right, such as account records and service logs.

IV Talent operates under United States and South Carolina law. Where a client or its people are in the UK or the European Economic Area, their information is handled in line with applicable data protection law, including the GDPR, and the rights described below apply to them in full.

Questions, requests and complaints can be sent to support@iv-talent.com.

This tool exists to support coaching by a human coach. Everyone using it has already agreed to be coached by that coach, and the coaching relationship is between the person, their team and the coach. Private here means private from colleagues, team leaders and administrators. It does not mean hidden from the coach, who needs to hear what was said in order to do the work.

The tool is built around a simple separation, and it is the best summary of how information is handled.

• Private. Coaching conversations, personal notes and a person's own working picture stay between that person and the assigned coach. Other members, team leaders and administrators cannot read them.
• Chosen sharing. Anything that moves from the private layer into the team layer is either approved by the person it belongs to, or reduced so that it no longer identifies them. Approval is recorded, and it can be withdrawn.
• Open. Some things are attributed by design, such as named feedback, posted priorities and requests for help. Where that is the case, the tool says so before anything is sent.

Coaching conversations are spoken, recorded and turned into a written record so the coaching can continue from one session to the next. Signing in confirms agreement to that recording and processing. Anyone who would rather not be recorded should speak to their coach instead of using the tool.

• Account details: name, work email address, team and role.
• Coaching sessions: the spoken conversation and the written record of it.
• Notes, documents and links a person or a team adds.
• Workload and priority entries, and any approvals given to share them.
• Named feedback and other openly attributed contributions, including corrections.
• Technical records needed to run and secure the service.

To provide coaching to each person, to give a team a shared picture of how it works, to keep accounts secure, and to meet legal obligations. Where the organisation is responsible for the tool, it relies on its own lawful basis, usually its legitimate interest in supporting and developing its teams, and it should explain that in its own staff privacy information. Where a person chooses to share something from the private layer, that sharing rests on their choice and can be withdrawn.

Access is enforced at the data layer rather than only in the interface. Team leaders see the team layer, not private coaching content. The team's assigned coach can also see the conversations behind a team pattern, so that the coaching is grounded in what was actually said. Administrators can manage access and settings; that is not the same as reading private material. Access to the underlying systems is restricted to the small number of people who need it to run the service, and is logged.

A small number of specialist providers support the service: hosting and database infrastructure, speech and language processing for the coaching conversation, email delivery, and error monitoring. They act on instructions, are bound by confidentiality and data protection terms, and receive only what they need. Because IV Talent and some of its providers are based outside the UK and the European Economic Area, information may be processed in the United States and elsewhere; where it is, contractual safeguards appropriate to that transfer are in place. A current list of providers, with the safeguards that apply, is available on request. Information in this tool is not sold, and it is not used to train third party models.

Nothing is kept beyond the coaching assignment. When the assignment ends, the records that belong to it are deleted. The limits we work to are:

• Audio of a coaching conversation: deleted within 7 days of the session.
• Written records of coaching, personal notes and a person's working picture: kept for the duration of the coaching assignment, then deleted within 30 days of it ending.
• Team layer content, including shared patterns, priorities, feedback and uploaded material: deleted within 30 days of the assignment ending.
• Records of what was agreed or approved, and of approvals withdrawn: kept for 12 months after the assignment ends, then deleted.
• Account records: deleted within 30 days of an account being closed.
• Invitations that are never accepted: deleted after 60 days.
• Technical and security logs: kept for 90 days.

Anyone can ask for a copy of their own recordings and records, or ask for them to be deleted, at any time. Requests go to the address above and are answered within 30 days.

People in the UK and the European Economic Area have rights under applicable data protection law to access their information, correct it, have it deleted, restrict or object to its use, and receive a copy in a portable form. Where the organisation is responsible for the tool, requests are usually made to that organisation, and IV Talent supports it in answering them. Requests can also be sent directly to the address above and will be passed on where appropriate. There is also a right to complain to a data protection regulator, which in the UK is the Information Commissioner's Office.

People elsewhere can make the same requests to the address above, and they will be answered on the same basis.

Accounts are individually authenticated, access is approved before the tool can be used, and separation between the private, shared and open layers is enforced by the system itself. Traffic and stored content are encrypted. No service can promise perfect security, and anything genuinely sensitive about a person's health, personal circumstances or legal position is best kept out of the tool.

This notice is updated when the tool changes. The date at the top shows the current version.