This document explains how Quadrangle Consulting Services Pvt. Ltd. collects, handles, uses and discloses personal information collected through use of:
- Assessor led assessment activity (example:assessment centers)
- Online tools owned by QC (Administered in paper pencil format or via survey monkey)
- Cubiks IBO limited products and services.
For assessments delivered by QC via an assessor led activity or via online tools owned by QC – QC follows the data privacy rules of India and maintains the highest level of care in the collection, management, storage and use of participant and client data. We used appropriate consent forms from the client organization and individual participants before any data is collected. This provides complete transparency to the participants and the client organization on what data will be collected, how and where it will be shared and how the data will be used to meet the objectives of our assignment.
For online tools owned by Cubiks IBO limited – As an authorized agent of Cubiks IBO Limited,our information handling practices are continually reviewed to ensure they comply with all applicable laws, regulations and standards relevant to Cubiks IBO Limited.(Agreement between Cubiks IBO and Quadrangle Consulting Services Put Ltd is attached)
- “Customer/Client” means the organization using services and products of Cubiks
- “Participant” means the individual who is taking the assessment
- “QC” meansQuadrangle Consulting Services Pvt Ltd
- “Cubiks” means “Cubiks IBO Limited”
- “Data subject” means the individual whose personal information is collected.
- “Products owned by QC” cover
- Range of aptitude tests
- Range of business case studies and role plays
- Range of functional assessment tests / tools
- Range of situational job questionnaires
- Any parts or combinations of the above
- “Products and Services of Cubiks IBO” means offerings from Cubiks which covers the following tools
- PAPI 3
- Any parts or combinations of the above
- “Personal Information” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with QC, can identify such person.
- “Sensitive Personal Information” of a person means such personal information, which consists of information relating to
- Financial information such as bank account or credit card or debit card or other payment instrument details
- Physical, physiological and mental health condition
- Sexual orientation
- Career history
- Medical records and history
- Biometric information
- Any of the information received under above clauses by QC for processing, stored or processed under lawful contract or otherwise.
- Any information that is freely available or accessible in public domain or furnished under the Indian Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Sensitive Personal Information for these purposes.
- This personal information or sensitive personal information may be that which is collected/received/possessed/stored/dealt in/ handled by QC
- Sensitive personal information is a subset of personal information. Hence, wherever sensitive personal information is not mentioned separately in this document, it is deemed to be included under personal information. Consequently, all that is applicable to personal information is automatically applicable to sensitive personal information.
- “Service Providers” mean contractors, consultants and agents that help QCto provide its services as defined in the Services Agreement between Cognizant and QC.
QC may collect Personal Information in any of the following ways:
Direct input by the customer/ client/participant – In order to use products and services the customer (products of Cubiks IBO/ QC; assessor led assessment services of QC)is required to provide certain personal information(like full name, e-mail ID, location, current designation, gender etc.). If the customer/participantdoes not provide certain information, the participants will not be able to access and /or complete the assessment exercise. This information is clearly identified at the point of collection.
Indirect input by the customer/ client/participant – This information we get from the customer use of Cubiks IBO/ QC Products and Services.
For access to Cubiks IBO / QC online products,Cubiks/ QC may collect device-specific information, such as operating system type and/or mobile device model, browser type, domain, and other system settings, the language the customer system uses and the country and time zone of the customer device, geo-location, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information.
Inputs by Customers/participants – Customers/participants provide information to access the product (example- level,gender, location, language preference, nationality etc.) , including personal information that customers hold and are authorized or entitled to disclose.This information is collected on and saved on the Cubiks online platform/ QC system / survey monkey platform.
For the purposes of the assessment, the organisation may share information on the participant’s performance and career history. Such data is used for the purposes of the project. The data is not shared in any alternate format with anyone outside the client organisation and with anyone apart from the parties listed in the participant consent form. The use of such data is limited to the purpose of the project.
Choice – Where applicable, QC will offer the customer/participantwith choice to not provide an information. The mechanism of this will be made available within the course of service.
INFORMATION PURPOSE AND USE
We use the information collected for following purposes:
- Providing Cubiks / QC products and services to customers.
- Supporting the customer in performing the services as and when requested by the customer
- Improving Cubiks/ QC Products and Services by performing analytics, research on the data collected.
- Reaching out for furthering business opportunities/value additions to the customers from time to time.
Assessment data generated in assessor led assessment services of QC is –
- Shared with participants via a report that is considered confidential to them. Before the survey, participants are informed about the kind of report that the assessment will generate and to who all (other than the participant) the report will be shared with.
- Sharing of reports with personnel (other than the participant) (within or outside your organisation) is intimated to the participant before they access such an assessment and is a part of the consent from that the participant fills before the assessment is enabled.
- Data from the survey and assessment can be converted into a group report for purposes of training needs analysis and other group indices. This data will be presented to internal departments of the organisation as per our contractual commitment towards the project. The consent form that the participant’s fill includes the mention of group analysis and the parties it will be shared with along with its purpose. The participants have the right to exit the assessment or withdraw from it should they have objections with the use of their data.
- QC shall protect, keep confidential and no sell/share any sensitiveinformation gained directly from customer/ participant during coaching and other assessor led services.
- To Service Providers-We may share customer/participant’s personal information with our service providers. Our Service Providers will be given access to such information as is reasonably necessary to provide their services. If Service Providers acquire personal information belonging to QC or customer/participant, such information is required to be handled in confidence by them and not be disclosed to unauthorized external parties by them. All service providers have appropriate contracts privacy documents signed with us which include a commitment towards data privacy.
- To government agencies and statutory bodies– If the government agencies or statutory bodies seek customer/participant personal information, we may be required to disclose itfor verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences. This disclosure will be done only after following due processes laid down by applicable laws.
RETENTION AND DISPOSAL
- QC shall take reasonable steps to destroy or permanently de-identify personal information that it no longer needs.
QC shall provide an option to the customer/participant to communicate any change or correction to the personal information that the customer/participant has provided and ensure that any of such personal information found to be inaccurate or deficient shall be corrected or amended after following due process.
- Data collected directly by QC will be saved in our system in India.
- Data collected by Cubiks via online assessment is saved and stored on Cubiks Online and on servers located in UK.
- About the Cubiks IBO products/services -QC follows Cubiks security practices and procedures to protect the customer’s/participant’s personal information from misuse, loss and unauthorized access, modification or disclosure.
- Without prejudice to the generality of the forgoing,QC ensures that it and all its personnel and employees-
- Only process personal data in accordance to instruction of Cubiks or any affiliate and the customer and only as required for purposes of the services/product delivered to the customer
- Not intentionally do or permit anything to be done which might jeopardize or contravene compliance by Cubiks, any affiliate, any licensee or any Cubiks customer with the data protection legislation and
- Without prejudice to the forgoing to
- Take appropriate organizational measure against the unauthorized or unlawful processing of personal data.
- Take reasonable steps to ensure compliance with those measures
- Comply with Cubiks data security policy as may be revised from time to time
NOTIFICATION OF CHANGES
If at any point, we decide to use personal information in a manner different from that stated at the time it was collected, we will notify the customer by email.
COMPLAINTS AND QUERIES
For any further queries and complaints related to privacy, contact Grievance Officer. The details are:
Name: Mr.Bawa Grover
Contact No.: +919560629777
Postal Address: Suite 117, 118 , 1st floor Star Tower, Sector 30, Block A NH 8 , Gurugram , Haryana 122003