This Privacy Policy explains how Empathy Edge Solutions (EES), operated by JCTC Pty Ltd ATF Horne Enterprises Family Trust (ABN 63 142 598 723), collects, holds, uses, discloses and protects personal information in connection with our website, enquiries, client engagements, workshops, advisory work, evaluation activities and business operations.
EES is committed to handling personal information responsibly and transparently. To the extent the Privacy Act 1988 (Cth) and the Australian Privacy Principles apply to EES, we comply with those requirements. Where they do not apply, this policy describes the standards EES intends to follow in practice.
In this policy, “personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
1. Who this policy applies to
This policy may apply to personal information about prospective and current clients and their representatives; workshop participants; people completing EES evaluation or feedback activities; people who make enquiries; suppliers, contractors, advisers and business contacts; people who subscribe to EES communications; and other individuals whose information is legitimately provided to EES in connection with an engagement.
2. What personal information we may collect
The information EES collects depends on how you interact with us. It may include:
- identity and contact information such as name, role, organisation, email address and telephone number;
- business and professional information relevant to an enquiry or engagement;
- information about the capability challenge, participant group or organisational context;
- workshop registration, attendance and participation information;
- survey, evaluation, feedback and follow-up responses;
- communications with EES, including correspondence, meeting notes and agreed actions;
- billing, payment and administrative information;
- marketing preferences and records of consent or opt-out requests; and
- technical information generated when you use our website, such as device/browser information, IP address, cookies and analytics data where enabled.
EES may occasionally receive sensitive information where it is relevant to a legitimate engagement. We seek to minimise collection of sensitive information and ask clients and participants not to provide detailed personal case information unless it is genuinely required and appropriate safeguards are in place.
3. How we collect personal information
EES usually collects personal information directly from the individual when you submit an enquiry, participate in a discovery or client meeting, register for or attend a workshop, complete an evaluation or feedback activity, correspond with us, subscribe to communications or interact with our website.
We may also receive information from an organisation engaging EES, an authorised representative, a referrer, a service provider or another person where it is reasonable and appropriate in the circumstances.
If EES receives unsolicited personal information that we do not reasonably need, we may securely delete or de-identify it where lawful and practicable.
4. Why we collect and use personal information
EES may collect, hold, use and disclose personal information for purposes including:
- responding to enquiries and determining whether EES is a suitable fit;
- scoping, proposing, contracting for and delivering EES services;
- communicating with client contacts and participants before, during and after an engagement;
- tailoring delivery to a client’s organisational context without collecting more information than reasonably required;
- administering workshops, participant materials, attendance and logistics;
- conducting baseline, immediate post-workshop and follow-up evaluation;
- analysing de-identified or aggregated outcomes to improve EES products and demonstrate program effectiveness;
- issuing invoices, receiving payment and maintaining business records;
- managing safety, risk, complaints and legal or contractual obligations;
- protecting EES intellectual property and enforcing agreements; and
- sending relevant business or marketing communications where permitted, with a simple way to opt out.
EES will not sell personal information.
5. Workshops, evaluation and client reporting
EES uses evaluation to understand whether capability has changed, not simply whether participants enjoyed a workshop.
The way evaluation information is handled will be explained in the relevant collection notice or survey instructions. Depending on the engagement, an evaluation may be anonymous, confidential but identifiable, or identifiable for a specific agreed purpose.
Where an evaluation is described as anonymous, EES will not intentionally ask for information designed to identify the participant in that instrument. Where responses are confidential but identifiable, access will be limited and client reporting will ordinarily use aggregated or de-identified results unless another arrangement has been clearly agreed.
EES may use de-identified and aggregated data from engagements to improve its services, evaluate The Human-First Response™ and communicate evidence of outcomes. EES will not identify a client organisation or participant without appropriate authority or consent.
6. Sensitive workplace information
EES is a manager-capability and advisory business. We do not need full case files or detailed personal histories for most enquiries or workshops.
Clients and participants should provide only the information reasonably required for the agreed purpose. Where realistic scenarios or examples are used, EES may ask that material be de-identified or altered to reduce unnecessary personal information.
If EES determines that sensitive or identifying information is necessary for a particular advisory task, we may agree additional handling arrangements with the client, including secure transfer methods, access restrictions and retention expectations.
7. When we may disclose personal information
EES may disclose personal information where reasonably necessary to the client organisation or its authorised representatives; technology, cloud, email, website, survey, accounting, payment, document-management or other service providers that support EES operations; contractors or facilitators who need the information to perform agreed work; professional advisers or insurers; regulators, courts or other parties where required or authorised by law; or another party with the individual’s consent or where otherwise permitted by law.
EES seeks to limit disclosures to what is reasonably necessary for the relevant purpose.
8. Website hosting, form processing and overseas processing
The EES website is hosted using Netlify. Website enquiry submissions are processed through Netlify Forms before being accessed by EES. Netlify may store or process website and form information using infrastructure outside Australia. EES therefore asks users not to submit confidential, identifying or sensitive details about individual workplace matters through the website enquiry form.
EES may also use other reputable technology and cloud service providers that store or process information in Australia and, in some cases, overseas. Depending on the systems used at the relevant time, overseas processing may occur in jurisdictions used by those providers.
Where overseas processing is relevant, EES will take reasonable steps appropriate to the circumstances to understand and manage the privacy and security risks associated with those providers.
9. How we protect personal information
EES takes reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. Measures may include access controls and multi-factor authentication, secure cloud services, device security, limiting access to people who need information for the relevant task, using de-identified information where practical, secure disposal or deletion processes and confidentiality obligations for relevant providers and contractors.
No method of electronic transmission or storage is completely risk-free. EES therefore combines technical controls with data minimisation and practical handling rules.
10. Retention and deletion
EES retains personal information only for as long as reasonably required for the purpose for which it was collected, legitimate business and recordkeeping needs, dispute management, contractual obligations or applicable law.
When personal information is no longer reasonably required, EES will take reasonable steps to securely destroy or de-identify it, subject to any legal or contractual requirement to retain it.
11. Website, cookies and analytics
The EES website may use cookies and similar technologies to operate the site, remember preferences, understand website performance and improve user experience. Analytics services, if enabled, may collect technical information such as browser, device, IP address and website interactions.
EES does not intend to use the website enquiry form to collect detailed sensitive workplace information.
12. Marketing communications
EES may send relevant business updates, invitations or information about services where permitted by law and where the recipient has consented or it is otherwise reasonable to do so.
Commercial electronic messages will identify EES and provide a clear way to unsubscribe.
13. Artificial intelligence and automated tools
EES may use technology-assisted tools to support administrative, drafting, analysis or business processes. Where such tools are used, EES aims to minimise the personal information provided and to use de-identified information where practical.
EES does not currently arrange for a computer program to use personal information to make a decision that could reasonably be expected to significantly affect an individual’s rights or interests. If that position changes, EES will review and update this policy and any required notices before the relevant use begins.
14. Third-party websites and services
The EES website or communications may link to third-party websites or platforms. Those third parties operate under their own privacy practices and terms. EES is not responsible for the privacy practices of third-party sites.
15. Accessing or correcting your personal information
You may contact EES to request access to personal information we hold about you, or to ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading.
We may need to verify your identity before providing access or making a correction. In some circumstances, access may be refused or limited where permitted by law.
16. Privacy questions and complaints
Empathy Edge Solutions
Operated by JCTC Pty Ltd ATF Horne Enterprises Family Trust
ABN 63 142 598 723
Sunshine Coast, Queensland, Australia
If you have a question, concern or complaint about how EES has handled personal information, please contact hello@empathyedge.com.au.
Please provide enough information for us to understand the issue. EES will review the matter, may ask for further information where needed, and will seek to respond within a reasonable period.
If the Privacy Act applies to the matter and you are not satisfied with our response, you may be entitled to complain to the Office of the Australian Information Commissioner.
17. Data breaches
If EES becomes aware of a suspected data breach, we will take reasonable steps to contain the incident, assess what occurred and reduce the risk of harm.
Where the Notifiable Data Breaches scheme or another applicable legal or contractual notification requirement applies, EES will assess and notify affected individuals and/or the relevant regulator as required.
18. Children and young people
EES services are primarily designed for organisations and adult managers, leaders and workplace participants. EES does not knowingly seek personal information directly from children through its general website or marketing.
19. Changes to this policy
EES may update this Privacy Policy when our services, systems, legal obligations or information-handling practices change. The current version will be published on our website with its effective date.