Winsborough Best Practice Guidelines for Confidentiality and Privacy
Winsborough provides leadership solutions for use in individual, team and organisational selection, development, and leadership activities. We design and use leadership assessment tools (including, but not restricted to, the assessment of individuals' behaviour, preferences and abilities by themselves and others) to meet our clients' needs and (once anonymised) for our own research purposes.
We are committed to protecting privacy and ensuring that we handle any personal information with care and respect. We act in accordance with the principles of the Privacy Act (2020) and the New Zealand Psychologists Board Code of Ethics to safeguard personal information.
While Winsborough is not responsible for your organisation’s privacy practices, we do partner with you to provide effective services. We designed these guidelines to help you keep your participants fully aware of why their personal information is being collected, what will happen to it, and who will have access to it once it has been collected. We ask that you act in accordance with these Best Practice Guidelines when using our services.
Compliance with the Privacy Act (2020) means organisations must take all steps possible to ensure individuals providing personal information are aware of the following:
Ensure individuals are fully aware of the purpose for which their information is being collected and what they are consenting to. For example, information collected as part of a selection process may also be later used for development purposes for the successful person. In addition, all information collected by Winsborough may be anonymised, and used for research purposes and / or to create aggregate data for your organisation to make better people decisions.
Ensure individuals have in writing who will have access to their personal information. For example, in selection purposes this may be “all members of the selection panel”, or for development it may be the individual’s manager and relevant members of the Human Resources team.
When personal information is collected verbally, it is also important to ensure that confidentiality and informed consent are re-visited. For example, confirming in an assessment feedback session if the conversation needs to be kept confidential to those in the meeting, or whether it can / will be shared with others outside of the meeting.
The general rule of thumb is that personal information should be stored for as long as you require. In selection for unsuccessful external candidates this could be until the end of the selection process. For successful candidates, this could be for the duration of their employment. We also recognise that government organisations have other legal obligations regarding storage of personal information.
All personal information should be securely stored either in locked drawers or filing cabinets or online on a secure system that will protect the individual’s confidentiality. Psychometric data should be stored separately from an individual’s general personal file. This is to safeguard the confidentiality of personal information, as in many organisations several different people will have access to a general personal file, for example those working in payroll, and are unlikely to have been included in the informed consent.
Individuals have the right to access and correct factual (not evaluative) personal information to ensure it is accurate and up to date. They should be informed that they can do this, and the process to follow.
Individuals need to be aware of any consequences if they chose not to provide personal information. For example, in a selection process, the outcome may be impacted as the information the panel has to make their decision on the individual is more limited. If you have someone who is nervous about completing assessments, we can support you by providing them with more information about the assessments (what they measure and how they will be used).
If there are any changes to the sharing, storage or who will have access to personal information after initial consent, individuals need to be notified and consent renewed in writing to reflect the changes. If the person chooses not to consent to the changes, this should be respected, and the original consent conditions upheld.
There may be instances where individuals are asked to volunteer the contact details of a third party to provide an independent assessment. For example, when completing a 360-feedback tool. In these cases, the organisation and individual are responsible for informing the third party that their contact details and personal information will be disclosed. When possible, their prior consent should be obtained before disclosing their personal information.
Quick Checklist for Consenting
Before you set up any assessments, you should be able to answer the below questions, and share them with all people involved in the process. This is likely to including key sponsors, the individuals whose personal information you are collecting, and the people setting up the assessments.1. Why are you collecting personal information?
(ie. the purpose - for personal development or as part of a selection process)2. How will you collect their information?
(ie. through Winsborough’s platform Ka tipu te Rangatiratanga)3. Who will you be sharing their information with?
(ie. all parties included in a selection process, or their manager and HR BP)4. Where and how will their information will be stored securely?
(ie. on the HR secure drive or it won’t be stored by P&C)5. How can they access their information to correct any factual errors?
(ie. contact their manager, Winsborough or the HR BP)
For 360 Assessments the following process is recommended to ensure participant well-being during the process:
Before sharing reports with participants it is recommended that your in-house 360 Accredited Practitioner reviews all verbatim comments to ensure there are no comments that could be deemed potentially harmful or destructive to the report participant.
In the rare instance where a comment is identified as potentially harmful or destructive, in the first instance Winsborough recommends that you contact the rater who wrote the comment and ask them to either:
- alter the comment to be more constructive, or
- remove the comment.
- If the rater indicates that they would like the comment to remain as first written, we recommend that you consult your in-house experts to ensure all confidentiality and ethical considerations are properly evaluated before publishing and sharing the report.
A little bit about us
Winsborough specialises in the business of leadership – selecting, developing, supporting and enhancing leaders across public and private organisations, both in New Zealand and globally.
Winsborough believes all employees deserve better leadership and strives to help make this happen. The team at Winsborough are dedicated to improving leadership and performance at all levels of the organisation: individual, group, team, and organisation-wide. Winsborough is an All of Government provider and can engage with eligible government agencies through this contract.