1. Purpose
This Privacy Policy (Policy) explains how 180 Degrees Consulting Limited and its affiliates (collectively 180DC, we, or us) collect, use, store, and disclose personal data, including recordings of interviews and meetings, and how you can exercise your rights over that data.
The Policy applies to all services, including consulting services, recruitment, Town Halls, business development interactions, and websites (collectively, the Service). It is designed to ensure transparency and accountability in line with applicable data protection laws, including the Australian Privacy Policy (APP) General Data Protection Regulation (GDPR).
2. Introduction
180DC values your privacy and cares about the way your personal data is treated. This Policy is intended to help you understand:
- what information we collect about you;
- why and how we use that information;
- how we protect it; and
- your rights regarding access, correction, deletion, and objection.
By interacting with 180DC, for example, applying as a volunteer, participating in Town Halls, or engaging in business development discussions, you acknowledge that you understand how your data will be collected and used as described in this Policy. Where applicable, you can withdraw consent at any time by contacting us at
legal@180dc.org.
3. Scope
This Policy applies to personal data collected from:
- volunteers and prospective volunteers, including through recruitment interviews;
- attendees of Town Halls or similar internal meetings;
- potential clients or business contacts participating in interviews or discussions;
- other individuals interacting with 180DC in the course of our services.
Personal data may include:
- contact details and identification information (e.g., name, email, phone);
- professional or educational history;
- audio/video recordings and transcripts;
- sensitive information voluntarily disclosed (e.g., health, political views, or other special categories).
4. How We Collect Data
We collect personal data directly from you or from third parties (e.g., partners or affiliates) where necessary. Common collection methods include:
- forms submitted online (e.g., volunteer applications);
- interviews (volunteer recruitment, business development);
- attendance and participation in Town Halls or internal meetings;
- emails, calls, or other communications; and
- online platforms or tools we use, such as Sana Labs for recordings, transcription, and AI-generated notes.
5. Lawful basis for Processing
We only collect and process personal data where we have a lawful basis under GDPR.
Legitimate Interests (Article 6(1)(f)) – Internal Operational Use
We use legitimate interests to process personal data where it is necessary for internal operations, including:
- volunteer recruitment interviews for note-taking and internal review;
- town halls for documentation and sharing with absent team members.
Safeguards include:
- limiting access to authorised personnel (GLT and branch leadership);
- recording speaker view and slides only;
- minimising retention (e.g., deleting recordings after a defined period unless required);
- allowing opt-outs (camera/mic off or request removal)
Legitimate interests are applied only after conducting a balancing assessment to ensure processing does not override your rights.
Consent (Articles 6(1)(a)) – External or High-Risk Use
Consent is required where recordings are:
- shared externally (e.g., marketing, testimonials, publication);
- part of business development interviews with clients;
- processing sensitive personal data or high-risk material.
Consent requirements:
- freely given, informed, specific, and unambiguous;
- provided through explicit opt-in (e.g., written confirmation);
- withdrawable at any time without affecting prior lawful processing;
- includes notification of any third-party processors, such as Sana Labs, and access to their privacy terms.
Contract
We collect and process personal data where processing is necessary to perform a contract with you, e.g., delivering consultancy services you requested.
6. Recordings and Transcripts
We use Sana Labs to record and transcribe interviews, Town Halls, or business development interactions in exceptional cases. These recordings involve processing personal data, such as voice, image, and any content disclosed during the session.
- Access: Restricted to authorised personnel (e.g., interviewer, 180DC Global Leadership Team etc.).
- Purpose: For internal operational efficiency, recruitment review, Town Hall documentation, or business development note-taking.
- Retention: Recordings are retained only as long as necessary and aligned with the active subscriber agreement with Sana, and are deleted unless explicitly required.
- Opt-out: Individuals may decline or stop recordings (e.g., camera/microphone off or request removal).
- Third-party transparency: For full details, see Sana Labs Privacy Notice and Sana Labs Data Processing Agreement.
Recordings are not routinely made. When they are, all participants are notified in advance via invite and verbally at the start of the session.
7. Data Retention and Minimisation
180DC only retains personal data for as long as necessary for the purpose collected. Non-essential data is minimised wherever possible.
Recordings and transcripts are deleted or anonymised after the defined retention period unless required for operational, legal, or contractual purposes.
8. Your Rights
You have the right to:
- access and obtain a copy of your personal data;
- correct or update inaccurate or incomplete data;
- request deletion (“right to be forgotten”) if lawful basis no longer applies;
- restrict or object to processing based on legitimate interests;
- withdraw consent where consent is the lawful basis;
- lodge a complaint with a supervisory authority.
How to exercise your rights:
You can contact
legal@180dc.org for any questions on your rights. We aim to respond within one calendar month, extendable by up to two months for complex requests.
For recordings processed via Sana Labs, you can also request removal of your recording or transcript at any time. While Sana stores data according to their Data Processing Agreement, 180DC retains ultimate responsibility for access and deletion under GDPR.
9. Third-Party Processors
We may use third-party services to assist with processing personal data, including:
- Sana Labs: For recording, transcription, and AI-assisted notes.
- Other providers: For operational or administrative purposes (e.g., IT support, billing).
Our responsibilities with third-party processors:
- they process data only on our instructions;
- confidentiality and security safeguards are implemented;
- they assist with data subject rights where required;
- full transparency is provided via this Policy.
We summarise the key points in plain language: recordings may be hosted by Sana Labs, retained during the agreement period, and processed only for internal or contractual purposes. External sharing or publication occurs only with your explicit consent.
10. Changes To This Policy
11. Contact
Questions, concerns, or requests regarding this Policy or your personal data can be directed to
legal@180dc.org.
.avif)
