Privacy Policy

1. What we collect

How we collect it

We collect most of this information directly from you, when you create an account, complete an assessment, or contact us.

Where you use Launch through a school or an employer, we also receive some information from them, such as your name, your school or work email address, and your year level or cohort. Technical information is collected automatically when you use the platform.

We collect only what the platform needs in order to work. Where we can provide something without collecting information, we do.

Sensitive information

We do not intentionally seek sensitive information through our assessments. We ask users not to include sensitive information in free text responses. If we identify sensitive information that we did not intend to collect, we will take reasonable steps to assess, restrict and, where appropriate, delete or de-identify it. Where reasonably practicable, we will also take steps to prevent unintentionally collected sensitive information from being used as an input to capability scoring.

2. How we use automated systems

Launch uses automated systems, including our capability engine, to analyse information provided through assessments and produce capability scores.

Information used by our automated systems

The information used may include your assessment responses, information derived from your responses, assessment timing and interaction data, and other information associated with your assessment where relevant to the assessment.

What the automated systems do

• The capability engine produces scores across the capability areas measured by the assessment. This analysis and scoring is done by software, not by a person reading each response.
• These scores may form part of your profile or credential, and may be provided to an employer where you have chosen to make your profile or credential available, or where you participate in an assessment conducted for that employer.
• Within the Launch platform, our automated systems produce scores and present information. They do not determine your eligibility for employment.

Decisions made by others

• Launch does not itself make the final decision to employ, reject or otherwise select a candidate. Those decisions are made by the relevant employer.
• Our scores may materially inform an employer's recruitment or selection process, but Launch does not make the employer's final decision.
• An employer may use our scores as an input into an automated or human assisted recruitment or selection process. Launch does not control how an employer uses those scores or what decision it makes.
• If you want to know how an employer used your scores, or to seek review of the employer's decision, contact that employer.

Asking about a score

You may ask us for information about how an automated score relating to you was produced, and may ask us to review the information used to produce it. We will provide information we can reasonably provide without disclosing confidential information, security information, or information that would materially compromise the integrity of the assessment.

3. Students under 18

Our student platform is provided to schools for their students, generally aged 14 to 18. We build it on the basis that the people using it are young, and we handle their information accordingly.

How students come to use Launch

• Where a student uses Launch through a school, we handle their information in accordance with our agreement with that school.
• Where a student uses Launch through a school, the school is responsible for obtaining any consents or permissions required under its agreement with Launch and applicable law. Launch remains responsible for its own obligations under applicable privacy law.
• We provide the school with a notice for students and a notice for parents and guardians, written in plain language, to be given before a student first uses the platform.
• We collect only what the platform needs in order to work. We do not ask students for information we do not need, and we ask them not to include sensitive information in their responses.

What we do not do with student information

• We do not make a student's capability information available to employers for recruitment purposes while the person is participating in the student platform.
• We do not sell student information.
• We do not use student information for advertising, for marketing to students, or to build a profile of a student for any purpose other than giving them their capability results and pathway guidance.
• Organisations that support the student platform may have their brand shown on scenarios in their industry. They have no access to student work, no ability to contact students, and no influence over scenarios or scoring.
• Students cannot contact each other through the platform, and there is no public student profile.

Later on

If a person later chooses to participate in Launch's candidate platform to look for work, that is a separate decision they make at that time. Their information is only made available to employers in accordance with their own choices and the notices provided at that point. Nothing carries across automatically.

Access and correction for students

A student can ask us what we hold about them and ask us to correct it. A parent, guardian or school can also ask, using the contact details below. Where a request comes to us directly from a student using Launch through their school, we will usually work through the school so that it can support them.

Our wider approach to protecting children who use the platform, including what we do if a student's response raises a concern for their safety, is set out in our Child Safe Policy.

4. How we use information

• to provide, secure, support and improve the service;
• to produce capability scores, results and credentials;
• to make your profile or credential available to an employer where you have chosen that, or where you participate in an assessment conducted for that employer;
• to communicate with you about the service;
• to process payments and keep the records we are required to keep;
• to meet our legal obligations and respond to lawful requests; and
• to develop, calibrate and improve our capability engine, as described below.

5. How we use information to improve our capability engine

Improving the accuracy and reliability of our capability engine is part of providing the service. We set out our position plainly.

We use responses and expert human rater judgements, in de-identified form, to test and improve our general capability engine. We keep customer-specific calibration information within the relevant customer's environment and do not use it to build models or benchmarks for another customer unless separately agreed in writing.

• We produce aggregated and de-identified statistical and benchmark information that identifies neither a customer nor an individual.
• We retain de-identified and aggregated information for as long as it remains useful, where no individual is reasonably identifiable from it.
• We do not sell personal information.
• We do not use personal information for advertising, or for marketing to students.
• We do not make student information available to employers while a person is using the student platform.

6. Who we share information with

• Your school or organisation, where you use Launch through them, to the extent set out in our agreement with them.
• Employers, where you have chosen to make your profile or credential available, or where you participate in an assessment conducted for that employer.
• Service providers who help us run the platform, including cloud hosting, email delivery, payment processing and analytics. They may only use the information to provide their service to us.
• Researchers, in de-identified and aggregated form only, for validation of the capability engine.
• Professional advisers, insurers and acquirers, where reasonably necessary and subject to confidentiality.
• Authorities and other parties, where required or authorised by law.

We do not sell personal information.

7. Overseas disclosure

Our platform runs on Amazon Web Services and personal information is stored in Australia, in AWS's Sydney region.

Some of the technology providers we use to operate the platform are located in, or operate from, the United States, and personal information may be disclosed to them in the course of providing the service. A current list of our service providers and the countries in which they operate is available on request from admin@launchapp.org.

Where we disclose personal information overseas, we take the steps required by Australian Privacy Principle 8, including putting contractual protections in place, to ensure the recipient handles it consistently with the Australian Privacy Principles.

8. How we protect information

• Our platform is hosted on Amazon Web Services, which holds ISO 27001, SOC 2 and other independent security certifications for its infrastructure.
• Information is encrypted in transit and at rest.
• Access is limited to people who need it for their role, protected by multi-factor authentication, and reviewed regularly.
• We log access to personal information and monitor for unusual activity.
• We maintain written security, access control, backup and incident response policies, reviewed at least annually.
• We follow the Notifiable Data Breaches scheme. If a data breach is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner.

No system is completely secure. We work to protect your information but cannot guarantee it will never be accessed without authorisation.

9. How long we keep information

We keep personal information only for as long as we need it for the purposes described in this policy, or for as long as we are required or permitted to keep it by law.

Where information is deleted, copies may remain in our backups for a limited period until those backups are cycled out. Backup copies are not used for any other purpose.

10. Credentials

If you issue a credential, we retain the limited information necessary to verify whether that credential is valid, expired or revoked. You may revoke a credential at any time.

If you later delete your account, that limited verification record may remain for as long as reasonably necessary to maintain the integrity of the credential system, currently 7 years. We tell you this, and what the credential contains, before you issue it.

11. Your choices and rights

• Access. You may ask for a copy of the personal information we hold about you. We will respond within the timeframe required by applicable law.
• Correction. You may ask us to correct personal information that is inaccurate, out of date, incomplete, irrelevant or misleading.
• Deletion and de-identification. You may ask us to delete personal information we hold about you. We will consider your request in accordance with applicable law. Some information may need to be retained where required or permitted by law, or where reasonably necessary to maintain the integrity of our services, including credential verification, security records and legal records.
• Automated systems. You may ask us for information about how an automated score relating to you was produced, and ask us to review the information used to produce it, as described in section 2.
• Employer visibility. Where you participate in the candidate platform, you control whether your profile and credential are visible to employers, and you can change that at any time in your account settings.
• Marketing. You may opt out of marketing communications at any time using the link in the message or by contacting us.

We may need to verify your identity before acting on a request. If we refuse a request, we will tell you why and how to complain.

12. Complaints

If you have a privacy concern or complaint, contact us at admin@launchapp.org. We will acknowledge your complaint and respond within the timeframe required by applicable law.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner. Information about making a privacy complaint is at https://www.oaic.gov.au/privacy/privacy-complaints, or by telephone on 1300 363 992.

13. Cookies

We use cookies to keep you signed in, to keep the service secure, and to understand how the platform is used. You can control cookies through your browser. Turning off essential cookies will stop parts of the platform working.

14. Contact us

15. Changes to this policy

We update this policy as our service and the law change. The current version is always published on our website with the date it took effect. Where a change materially affects how we handle your personal information, we will take reasonable steps to tell you before it takes effect.