Privacy & anonymity

At ELLA HR, we believe honest feedback only happens when people feel safe. That’s why privacy and anonymity are built into how the platform works. ELLA HR is the platform provider. Your organisation is responsible for running the survey and deciding why and how employee data is used. ELLA HR processes data only on behalf of organisations.

1) We measure to improve — not to judge people

ELLA HR helps organisations understand patterns and themes at team or organisational level.

2) Results are protected against re‑identification

We don’t show dashboards for groups that are too small, and we prevent filter combinations that could make someone identifiable. To protect anonymity, we apply a minimum group size (at least 5). In some cases, stricter thresholds or suppression may be applied if there is a risk of re‑identification.

3) We collect only what’s needed

Only the minimum information required to send surveys and generate insights.

4) We keep data secure

Access is restricted by roles, connections are secured, and we apply appropriate security measures.

5) We don’t keep data longer than necessary

Retention periods are agreed with organisations, and data can be deleted or anonymised when appropriate. Employees have rights under GDPR (such as access or deletion). Requests are typically handled by the employer. We support organisations in responding to such requests.

6) Where is your data stored?

Data is hosted in the [EU/EEA / region]. If international transfers apply, we use appropriate safeguards such as Standard Contractual Clauses. Questions about privacy? Contact us by clicking the button below:

We know HR data is sensitive. That’s why ELLA HR is built with privacy and security as a foundation.

How we keep data safe:

• only the right people get access
• connections are secured
• we log admin activity
• we maintain backups and recovery procedures
• if something goes wrong, we act quickly and transparently

How we handle privacy:

• we process data only on behalf of organisations
• we don’t sell data, and we don’t use it for advertising
• we help organisations explain surveys clearly to employees
• we protect anonymity by limiting reporting and filtering

What we never do:

• Sell your data
• Use survey answers for ads
• Let managers see “who said what”
• Show results that could identify someone

The General Data Protection Regulation (GDPR) is the primary privacy law. This Code of Conduct describes the behavioural rules and minimum standards for all individuals working on behalf of Mijn HR Held BV | ELLA HR (including external developers and designers) who have direct or indirect access to personal data and/or confidential information. Its purpose is to ensure that Mijn HR Held BV | ELLA HR processes personal data in accordance with the GDPR and applies appropriate security measures aligned with industry standards.

1. Purpose & Scope

Mijn HR Held BV and ELLA HR process personal data solely to support clients with interim HR assignments, HR advisory projects, HR Support subscriptions, and through the ELLA HR dashboard for employee engagement surveys, pulse surveys, and culture assessments. Everyone working for Mijn HR Held or with the ELLA HR dashboard adheres to this Code.

This document explains what this means in practice and how we apply these principles.

2. Core Principles (GDPR Art. 5)

The core principles are the seven foundational GDPR principles. They form the heart of our compliance and are the basis of everything we do.

Lawfulness, fairness and transparency We process personal data only when there is a valid legal basis.

Purpose limitation Data is used only for clear, predefined purposes.

Data minimisation We collect and store only the data we truly need. Less is more.

Accuracy Personnel data must be correct and up to date.

Storage limitation Data is not kept indefinitely. Retention periods are agreed in advance, after which data is deleted or anonymised.

Accountability

Integrity and confidentiality We ensure strong protection against cyberattacks and handle client data with integrity. Because confidentiality and integrity are core values, we work with tiensecurity.nl (Information Security & Certifications – Tien Security).

Tien Security demonstrates that they:

• work according to defined procedures (structure, periodic ISMS meetings, regular risk analyses)
• continuously improve organisational and security processes
• anticipate external threats and keep information security up to date
• regularly monitor and evaluate security measures in line with ISO27001

Within Mijn HR Held BV and the ELLA HR dashboard, we use MFA (multi‑factor authentication). The ELLA HR dashboard also includes login and audit trails. Later in this document, you will find our incident response plan (what we do in case of a data breach).

3. Roles and Responsibilities

3.a. Mijn HR Held BV | ELLA HR typically qualifies as a processor when delivering HR services and the ELLA HR dashboard to clients. The client usually qualifies as the controller. 3.b. Mijn HR Held | ELLA HR processes personal data only based on documented instructions from the client, unless legal obligations require otherwise. 3.c. All team members are responsible for complying with this Code and for immediately reporting incidents, potential data breaches, or compliance risks.

4. Confidentiality & Access Management

4.a. Access to systems and data is role‑based and limited to what is necessary (“least privilege”). 4.b. Login credentials are strictly personal and may not be shared. 4.c. Administrative access is protected with multi‑factor authentication (MFA) where possible. 4.d. Access to production environments is logged and periodically reviewed.

5. Data Minimisation & Data Quality

5.a. The ELLA HR dashboard collects and processes only the personal data necessary for:

• distributing surveys
• analysis and reporting at aggregated level
• (optional) improving services based on anonymised or aggregated insights

5.b. Personal data in the dashboard is anonymised and non‑identifiable. 5.c. Mijn HR Held BV | ELLA HR supports clients in keeping team structures and personnel lists up to date to prevent incorrect or identifiable reporting.

6. Anonymity & Reporting Protection

6.a. The ELLA HR dashboard applies minimum group sizes (e.g., n≥5 or n≥7) for reporting. 6.b. ELLA HR prevents re‑identification through suppression and aggregation rules. 6.c. Open text fields are designed to minimise the risk of sharing personal data (e.g., warnings, filtering, or summarisation).

7. Retention & Deletion

7.a. Retention periods are defined and documented for all data categories. If clients wish to run a follow‑up survey the next year for comparison, this is agreed in advance. 7.b. Personal data is not kept longer than necessary or is anonymised in time. 7.c. Deletion and export occur based on client instructions, according to agreed timelines and SLAs.

8. Security (Integrity & Confidentiality)

8.a. ELLA HR applies appropriate technical and organisational measures, including:

• encryption in transit and, where appropriate, at rest
• secure development practices
• monitoring, logging, and backup policies
• vulnerability management and patching

8.b. Mijn HR Held | ELLA HR documents security measures and reviews them periodically.

9. Incidents & Data Breaches

Any suspected incident or data breach must be reported internally immediately via privacy@ellahr.com. It is also reported within 72 hours to the relevant supervisory authority. Mijn HR Held BV | ELLA HR investigates incidents, takes mitigating actions, and informs the client in line with contractual agreements. All incidents are documented.

Rights of Data Subjects (DSAR)

Mijn HR Held | ELLA HR supports clients with data subject requests (access, deletion, etc.) insofar as this fits the processor role. Requests are forwarded to the client as controller unless agreed otherwise.

Sub‑processors & International Transfers

Mijn HR Held BV | ELLA HR uses only sub‑processors with appropriate contractual safeguards. If data is transferred outside the EEA, appropriate mechanisms (such as SCCs) are applied and documented.