Personal Data Notice
What we hold, and on whose instruction.
This notice covers personal data inside the Compass systems a client organisation adopts — talent acquisition, 360° diagnostics, meeting records and the delivery boards. It sits alongside the site privacy notice and the IT Security Policy, and travels with every engagement.
Compass Performance Consulting, Inc.. Version 1.0.0, effective 19 August 2026. Companion documents: IT Security Policy, System Use & Data Processing Agreement and the site privacy notice.
Controller and processor
Where a client organisation adopts a Compass system, that organisation determines why the data is held and is the controller. Compass acts as its processor, on its written instruction, and does not use the data for any purpose of its own. Where a person deals with Compass directly — an enquiry, a complimentary profile — Compass is the controller and the site privacy notice applies.
Contact: 500 West Silver Spring Drive, Suite K-200, Glendale, Wisconsin 53217, United States. skopecky@compassperformanceinc.com, 224.307.0912.
System by system
| System | Role | Data and subjects |
|---|---|---|
| Compass Talent Acquisition System™ (CTAS™)Requisition setup, posting, pre-screen, application intake, candidate review and rating, interview evaluation, offer and onboarding. | Client is controller; Compass is processor | Applicant identity and contact detail, résumé/CV content, work history, pre-screen answers and scores, interview evaluations, star ratings, disposition reasons, voluntary character-reference responses, offer and onboarding records.External applicants, internal candidates, referees, client hiring staff.Voluntary self-disclosures (for example state-specific notices and accommodation requests) are held separately from selection records and are not used in scoring. Pre-screen questions are drawn from the governed question bank and screened against forbidden subjects. |
| Compass 360° diagnostics (Eight-Area, Five Marks™, Enterprise Leadership 360)Nominate raters, collect ratings and comments, and release governed reports to the client through a Compass Administrator. | Client is controller; Compass is processor | Participant and rater identity, rating responses, free-text comments, completion status, report content and release history.Client executives, managers, individual contributors and nominated raters.Confidentiality thresholds suppress any group result below the configured minimum rater count. Individual rater identity is never released by name. Only a Compass Administrator may generate, filter, approve, release, download or print a report. |
| Meeting Desk and HyNote summariesTurn a session recording or pasted transcript into Compass minutes, decisions, owners and actions, then file the artifact and its shareable link. | Client is controller; Compass is processor | Participant names and roles, transcript text, meeting content, decisions, actions and owners, and the derived summary.Meeting participants and anyone discussed in the session.Recording and transcription happen only with the host's disclosure to participants. AI tools are used to draft, never to decide. See IT Security Policy Section 4.5. |
| Project, portfolio and value-stream boardsRun charter, stage-gate, risk, action and cadence records for a transformation program. | Client is controller; Compass is processor | Owner names and roles, task and action records, gate evidence, meeting cadence records and status notes.Client staff named as owners, sponsors or participants.Boards are working records, not performance records. Individual performance conclusions are not drawn from board data. |
| compassperformanceinc.com and complimentary profilesEnquiries, assessments completed on the public site, and published material. | Compass is controller | Name, work email, company, role, assessment answers and derived scores.Site visitors and prospective clients.Governed by the site privacy notice; a client's engagement data is never mixed into it. |
Meetings, recording and AI tools
Compass records or transcribes a session only when participants have been told in advance on the invitation. AI tools are used to draft, summarise and structure — never to make or automate a decision about a person. Every AI-assisted artifact is verified and approved by a named person before it is used or filed. Content submitted to an AI provider is not used by Compass to train models. The operating detail is IT Security Policy Section 4.5.
- For details on recording, transcription and AI tool use, see the Compass Personal Data Notice and IT Security Policy (Section 4.5).
- For disability accommodation, contact the meeting host in advance.
- For details on personal data use in meetings, see the Compass Personal Data Notice.
How long it is kept
Retention is client-directed. Absent a written instruction, Compass holds engagement records for 24 months from the close of the stage that produced them, then redacts identifying detail or deletes the record. On a written instruction, Compass returns or deletes the identified records within 30 days and confirms completion in writing, naming any record it must keep to meet a legal obligation.
Who else may see it
Only the service providers below, each under its own written processing terms, and only for the purpose stated. A new provider that will hold client-confidential material is notified to the client system owner before use, and the client may object.
| Provider | Purpose | Location |
|---|---|---|
| HubSpot | Client relationship records, meeting scheduling, and follow-up correspondence. | United States / European Union |
| Supabase (Lovable Cloud) | Application database, authentication, and encrypted file storage for the platform. | United States |
| Lovable | Hosting, delivery, and transactional email for this site and its instruments. | United States / European Union |
| ScoreApp | Complimentary Compass Profiles completed on the provider's own scorecard platform. | United Kingdom |
| Positive Intelligence | Licensed PQ® Mental Fitness program delivery for enrolled participants. | United States |
| YouTube (Google) | Video playback, loaded only when you choose to play a video. | United States / European Union |
| Publishing Compass articles and recording share clicks you initiate. | United States / European Union |
Rights and requests
A participant, candidate or employee of a client organisation should raise a request with that organisation, which instructs Compass. Compass supports the request and answers within the period the client's instruction sets. Anyone who dealt with Compass directly may use the privacy request form.
Stated limits
- Compass does not provide legal advice. Nothing in a Compass system, template, handbook, posting notice, pre-screen question bank or report is legal advice, and the client's counsel remains responsible for compliance with the law that applies to it.
- Employment decisions are the client's. Compass systems record, structure and evidence a decision; they do not make one. Selection, rating, disposition, offer, promotion, discipline and separation decisions are made by named client decision-makers.
- Compass makes no automated decision about any individual, and no Compass system profiles a person to produce a decision without human judgement.
- Compass does not warrant that a template, handbook document, job posting or notice satisfies the requirements of any particular jurisdiction. Templates are starting points to be reviewed by client counsel.
- Compass does not claim a certification, an external audit outcome, or compliance with any particular framework in these documents.
- Assessment and diagnostic outputs are inputs to judgement, not measures of a person's worth, and are not to be used as the sole basis for an employment decision.
This document is Compass's standard operating position, not legal advice. Compass is not your counsel. Have your own legal and IT functions review it before execution, and where an executed master agreement exists, that agreement controls.
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