This Privacy Notice is intended to describe the practices AKASH KARIA follows in relation to the High Performance Habits Quiz (“Tool”) with respect to the privacy of all individuals whose personal data is processed and stored in the Tool.
2. Who manages the Tool?
“AKASH KARIA” refers to the individual that is acting as data controller by providing this Tool on which your personal data will be processed and stored.
The Tool is hosted on servers in USA.
3. Why do we need your information?
The Tool will provide High Performance Habits survey to participants. The responses will be captured and held by Akash Karia who will provide them to senior management within EY in an aggregated and anonymised form who can use the results to create reports.
Your personal data processed in the Tool is used as follows:
• Information such as first name, last name is provided to Akash Karia so that they can distribute the survey and a personalised response.
• EY employees respond to survey questions distributed by Akash Karia.
• Akash Karia aggregates and anonymises the survey results against the information and is then used by specific EY personnel to produce a survey report which contains aggregated and anonymised results.
• The results of the survey are received e.g. by the relevant leader and then may be cascaded down to other managers within EY as necessary.
• The reporting is used to better the organisation and address areas of disengagement.
• The Tool is hosted on servers in USA.
Akash Karia relies on the following basis to legitimize the processing of your personal data in the Tool:
Processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. The specific legitimate interest pursued is to gather information which can improve the business and address areas of disengagement within the firm.
The provision of your personal data to Akash Karia is optional. However, if you do not provide all or part of your personal data, we may be unable to carry out the purposes for processing.
4. What type of personal data is processed in the Tool?
The Tool processes these personal data categories:
o Email address; and
o responses to survey questions.
This data is sourced from:
• Directly from EY Partners, employees or contractors.
5. Sensitive Personal Data
Sensitive personal data reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation.
The following sensitive personal data is collected and processed in the Tool:
• Health data (e.g. information which indicates an individual may have a sleep disorder).
This survey is optional and respondents do not have to answer any questions if they choose not to.
The legal basis for processing sensitive personal data is consent.
6. Who can access your information?
Your personal data is accessed in the Tool by the following persons/teams:
• Akash Karia
The access rights detailed above involves transferring personal data in various jurisdictions (including jurisdictions outside the European Union) in which Akash Karia operates (Hong Kong). Akash Karia will process your personal data in the Tool in accordance with applicable law and professional regulations in your jurisdiction.
The policies and/or procedures for the retention of personal data in the Tool are:
• Data is deleted as requested or within 12 months of taking the survey.
Your personal data will be retained in compliance with privacy laws and regulations.
After the end of the data retention period, your personal data will be deleted.
Akash Karia is committed to making sure your personal data is secure. To prevent unauthorized access or disclosure, Akash Karia has technical and organizational measures to safeguard and secure your personal data. All Akash Karia personnel and third parties Akash Karia engages to process your personal data are obliged to respect your data’s confidentiality.
8. Controlling your personal data
Akash Karia will not transfer your personal data to third parties (other than any external parties referred to in section 6 above) unless we have your permission or are required by law to do so.
You are legally entitled to request details of Akash Karia’s personal data about you.
To confirm whether your personal data is processed in the Tool or to access your personal data in the Tool, contact Akash Karia on email@example.com.
9. Rectification, erasure, restriction of processing or data portability
You can confirm your personal data is accurate and current. You can request rectification, erasure, restriction of processing or a readily portable copy of your personal data by contacting Akash Karia on firstname.lastname@example.org
If you are concerned about an alleged breach of privacy law or any other regulation, contact Akash Karia on email@example.com.
If you are not satisfied with how Akash Karia resolved your complaint, you have the right to complain to your country’s data protection authority. You can also refer the matter to a court of competent jurisdiction.
11. Contact us
If you have additional questions or concerns, contact us on: firstname.lastname@example.org