Data, privacy and AI

People are honest when they know it is safe

The questionnaire is anonymous, conversations are confidential, AI helps with the analysis and a Mploy consultant decides. Here you can read how we handle data and AI, so your works council and your legal adviser have their answers up front.

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How we handle data

Anonymous and confidential

The questionnaire is anonymous. Answers are stored without a name or email address, and even we cannot trace them back to a person. We only show figures once a group has at least five people, or three if your works council agrees in writing. If a team is smaller, it counts towards the total but we do not show it separately.

Anonymous and confidential

Conversations are confidential

Your consultant knows who they have spoken to. The report never contains a name, and a role or job title only if it occurs more than once; for a job that exists only once, it says ‘employee’. We remove details that could identify someone. We read open comments from the questionnaire ourselves first; only then, and from ten responses, do we share them, without identifying details.

Conversations are confidential

Only what is needed

We only ask for what we need for the scan. We keep data no longer than the engagement requires, as the GDPR prescribes, and delete it afterwards. We delete email addresses as soon as a survey round is closed.

Only what is needed

Stored in Europe

The database is in the European Union. The application runs at Infomaniak in Switzerland, which offers the same level of protection under the GDPR. For your legal adviser, a data processing agreement, a DPIA and the list of sub-processors are ready.

Stored in Europe

How we use AI

AI speeds things up, people decide

AI helps process conversations and answers. For this we use a language model from Mistral AI, a French company. Processing takes place in the EU, and Mistral does not train models on your data; that is set out in our contract. Names and email addresses are not sent to the AI. A Mploy consultant reviews everything, refines it and only then releases the report.

No decisions about individuals

AI does not assess individual employees and makes no statements about who should stay or leave. That is, and remains, human work.

Transparent to employees

Everyone who takes part reads beforehand what we measure, how anonymity works and what we use AI for.

Ready for the European AI rules

From December 2027 the European AI Act imposes strict requirements on AI that assesses, selects or ranks people. Our AI does not do that. It summarises conversations and answers and drafts a first version; the interpretation and the advice come from your consultant, who signs off by name on what you receive. That is why the Performance Scan does not fall into the high-risk category.

For your works council and legal adviser

Does your works council need to consent? Usually, yes: a recurring survey of employees with results per team generally falls under the right of consent in Article 27 of the Dutch Works Councils Act (WOR). That is why we involve the works council before the baseline. We provide the request for consent and a factsheet setting out what we measure, how anonymity is safeguarded and what happens to the data. We do not start the questionnaire without consent. A data processing agreement and a DPIA are ready.

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Questions about data or AI?

In a half-hour introduction we walk through the approach and answer the questions of your works council, legal adviser or IT department.