01 Scope & Commitment
Praxion Veritas ("we", "us", "our", or the "Firm") is an executive capability, leadership assessment, and strategic human capital consulting firm. This Privacy Policy sets forth our mandatory policies and practices concerning the collection, storage, processing, transfer, and protection of personal data and confidential diagnostic information obtained through our website (praxionveritas.com), our client advisory engagements, psychometric testing batteries, executive simulation labs, 360-degree multi-rater feedback instruments, and executive coaching interventions.
Depending on the context of the engagement, Praxion Veritas acts as both a Data Controller (for direct website inquiries, client relationship management, and direct advisory contracts) and a Data Processor / Data Fiduciary Intermediary (when delivering diagnostic assessments, talent mapping, and development center simulations on behalf of corporate enterprise clients who sponsor participant evaluations).
Regulatory Adherence
We operate in full compliance with applicable national and international data privacy frameworks, including the Digital Personal Data Protection Act, 2023 (DPDP India), the General Data Protection Regulation (EU GDPR / UK GDPR), and applicable global corporate privacy standards.
02 Categories of Data We Collect
To deliver talent analytics, leadership diagnostics, and advisory programs, we collect and process specific categories of information based on your relationship with us:
- Corporate Client & Stakeholder Information: Business contact details (name, organizational designation, corporate email address, business telephone number, billing address, tax identification numbers, and engagement contract documentation).
- Assessment Participant & Candidate Information: Professional profile data (full name, corporate email address, current role, functional domain, organizational hierarchy level, curriculum vitae/resume, educational background, and tenure).
- Diagnostic & Psychometric Data: Responses to standardized behavioral instruments, cognitive batteries, personality inventories (e.g., bright-side traits, derailer profiles, motivational drivers), situational judgment exercises, and simulation case study presentations.
- Multi-Rater & Observational Records: Quantitative rating metrics and qualitative narrative commentary submitted by peers, direct reports, supervisors, and cross-functional partners during 360-degree feedback processes, as well as assessor behavioral scorecards generated during Development Centers.
- Executive Coaching Records: Goal alignment notes, development action plans (IDPs), and session completion records. Note: Raw personal reflections shared in 1:1 coaching remain strictly privileged under Section 4.
- Technical & Website Usage Data: Internet Protocol (IP) addresses, browser characteristics, operating system versions, referring URLs, access timestamps, and session interactions gathered via essential cookies and analytics tools.
03 Psychometrics & 360° Multi-Rater Anonymity Protocols
Praxion Veritas implements stringent methodological safeguards to ensure the statistical validity, ethical integrity, and psychological safety of all participant diagnostic evaluations:
Multi-Rater (360°) Feedback Anonymity Threshold
To safeguard honest feedback and protect organizational dynamics, all narrative comments and numeric scores submitted by Peers, Direct Reports, and Other Stakeholders are strictly anonymized and aggregated into cohort averages. We enforce a mandatory minimum threshold of three (3) raters per rater category; if fewer than three responses are received, the data is automatically merged into a broader category to prevent individual attribution. Manager ratings are explicitly designated as non-anonymous by default to ensure accountable talent governance.
Psychometric profiles and simulation evaluations are used exclusively for legitimate organizational development, leadership bench evaluation, and succession planning within the defined scope authorized by the sponsoring client or participant.
04 Confidentiality in Executive Coaching & Assessment Centers
Our certified executive coaches and organizational assessors adhere rigorously to the ethical standards established by the International Coaching Federation (ICF) and the Association of Business Psychology (ABP):
- 1:1 Coaching Confidentiality: Personal discussions, vulnerable disclosures, private reflections, and internal notes taken by the coach during one-on-one executive coaching sessions are strictly privileged and confidential. Sponsoring corporate employers receive macro progress reports (e.g., session milestones completed, broad developmental themes, and coachee-agreed goals) but do not have access to verbatim session transcripts or confidential personal notes without the participant's explicit written authorization.
- Assessment Center Observations: Assessor behavioral scoring sheets and simulation feedback reports are shared only with designated organizational talent sponsors (e.g., CHRO, Talent Management Committee, authorized business leaders) and the participant in a structured debriefing session.
05 Legal Basis for Processing Personal Data
Under applicable data protection legislation (including GDPR Art. 6 and DPDP Act provisions), we process personal information pursuant to the following lawful grounds:
| Processing Purpose | Data Category | Lawful Basis |
|---|---|---|
| Execution of Corporate Diagnostic & Consulting Contracts | Client contact info, participant rosters, billing documentation | Performance of Contract (Art. 6(1)(b) GDPR / SOW fulfillment) |
| Administration of Psychometric & 360° Diagnostic Batteries | Assessment responses, behavioral observations, developmental scores | Legitimate Interests & Explicit Consent of Participant |
| 1:1 Executive Coaching & Leadership Capability Journeys | Individual development plans, session logs, progress metrics | Performance of Contract & Professional Consent |
| Website Inquiries & Briefing Requests | Inquiry form data, name, company, email, phone | Consent & Legitimate Interests (Pre-contractual) |
| Statutory Accounting, Tax & Audit Compliance | Invoices, payment receipts, commercial contracts | Compliance with Legal Obligation |
06 Third-Party Diagnostic Platforms & Disclosures
Praxion Veritas does never sell, lease, or commercialize personal data to any third party for marketing or unauthorized commercial exploitation. We disclose information strictly under the following controlled conditions:
- Authorized Psychometric & Diagnostic Software Platforms: We partner with industry-leading, enterprise-grade assessment scoring engines and psychometric test publishers. All such sub-processors are bound by executed Data Processing Agreements (DPAs) requiring ISO 27001 / SOC 2 Type II compliance and stringent data isolation.
- Accredited Senior Assessors & Coaches: Independent certified assessors, role-players, and executive coaches engaged by Praxion Veritas for specific mandates operate under strict non-disclosure, confidentiality, and data governance agreements.
- Sponsoring Enterprise Clients: Summary evaluation reports, capability scorecards, and development roadmaps are provided to the participant's authorized employer in accordance with the corporate Statement of Work.
- Legal & Statutory Mandates: Where compelled by valid legal process, judicial order, or regulatory authority having jurisdiction.
07 Data Security & Global Cross-Border Transfers
We implement comprehensive technical, organizational, and physical safeguards designed to prevent unauthorized access, alteration, disclosure, or destruction of confidential talent data:
- Encryption Standards: Data in transit is protected using Transport Layer Security (TLS 1.3), and diagnostic databases are encrypted at rest using AES-256 standard encryption.
- Access Controls: Role-Based Access Controls (RBAC), multi-factor authentication (MFA), and zero-trust administrative boundaries restrict data visibility solely to certified project personnel.
- International Data Transfers: When data is processed across international jurisdictions, we execute Standard Contractual Clauses (SCCs) approved by international regulatory bodies and ensure compliant cross-border data transfer mechanisms.
08 Data Retention Schedule
We retain personal information only for as long as necessary to fulfill the diagnostic, developmental, and legal purposes for which it was gathered:
| Data Record Type | Standard Retention Period | Disposition Action |
|---|---|---|
| Raw Psychometric Assessment Item Responses | 24 to 36 Months from assessment date | Secure permanent digital erasure or full anonymization for statistical norming |
| Executive Assessment Center Synthesis Reports | 36 Months or duration specified in Client Master Services Agreement | Archived under encrypted vaults or purged upon corporate client written directive |
| Executive Coaching Session Notes & Reflections | 12 Months following conclusion of coaching program | Permanent secure shredding / deletion |
| Website Inquiries & Proposal Correspondence | 24 Months following last active communication | Purged from active CRM repositories |
| Corporate Financial, Invoicing & Contract Records | 7 Years from transaction close | Retained per statutory corporate tax obligations |
09 Data Subject Rights
Depending on your jurisdiction, you possess defined statutory rights concerning your personal data held by Praxion Veritas:
- Right of Access & Confirmation: Request confirmation of whether your data is being processed and obtain a copy of your personal assessment profile.
- Right to Rectification: Request correction of inaccurate or incomplete demographic or background data.
- Right to Erasure ("Right to be Forgotten"): Request deletion of your diagnostic records, subject to client contractual terms and statutory record-keeping requirements.
- Right to Restrict Processing: Request the restriction of diagnostic data processing under specific contested circumstances.
- Right to Data Portability: Obtain an export of personal data you provided in a structured, commonly used, machine-readable format.
- Right to Withdraw Consent: Where processing is predicated upon voluntary consent, withdraw such consent at any time without retroactive effect.
Note regarding Corporate Sponsored Mandates: If your assessment was commissioned and paid for by your employer, Praxion Veritas processes your evaluation as a Data Processor. In certain scenarios, your statutory request must be directed to your sponsoring employer as the primary Data Controller. We will fully assist your employer in addressing authorized requests within statutory timeframes.
10 Cookies, Tracking & Web Analytics
Our website uses strictly necessary session cookies and privacy-respecting analytical telemetry to optimize page performance, maintain user session preferences, and evaluate website navigation pathways. We do not use third-party behavioral ad-targeting networks. You can configure your browser settings to decline cookies; however, certain interactive functional features of our digital interface may be impaired.
11 Policy Updates & Grievance Redressal
Praxion Veritas reserves the right to periodically update this Privacy Policy to reflect changing regulatory requirements, technological enhancements, or evolving advisory practices. Material changes will be communicated with an updated "Last Revised" date at the top of this document.
Data Protection Officer & Privacy Inquiries
To exercise your privacy rights, request data deletion, or submit a data protection inquiry or grievance, please contact our designated Privacy Office:
Praxion Veritas Talent Advisory
Attn: Data Privacy Officer (DPO)
Email: privacy@praxionveritas.com / info@praxionveritas.com
Response Time: Within thirty (30) business days from verified receipt.