Data Privacy Software Resources - Page 19

The KeenCorp software is comparable to a spam filter: the text of e-mails is automatically processed by the algorithm. For every text, sender-receiver details are anonymized up until the level of a pre-defined group (e.g. the groups ‘accounting’ or ‘management’) of at least 10 persons. In addition, for each processed text, names, place names and company names are automatically anonymized before processing. Finally, the only information stored is a single combined score or index, a number, for each defined group. As a result of this, a single measurement can never be traced back to an individual. This process is explained in more detail in the video (available from KeenCorp website). KeenCorp’s Privacy by Design is in fact comparable to 4 locks on the door to an empty room: 1. Anonymization and reference removal 2. Minimal group size 10 3. For each communication a single numeric index is calculated. This index is added to the average of the group, like a drop of water to a glass. Every day a combined score for every group is generated. 4. No content is ever stored. The ‘room’ is empty because KeenCorp doesn’t actually look at what is being written, but at the way it is being written. So, each individual’s privacy and confidentiality are 100% protected and the software is designed to do this. Individual communication content is never stored and scores can never be traced back to an individual. The KeenCorp’s algorithm does not look at personal content and content is never stored.

Protecting the privacy of the participants to the KeenCorp measurement is essential. For this purpose, the KeenCorp software was designed with this principle in mind. We call this Privacy by Design. This responds to strict privacy legislation, including the GDPR that has been applicable as of May 2018. The KeenCorp software complies in accordance with the 3 important principles: - Legitimacy: Is there a valid reason to perform the measurement? Our answer is ‘yes’, because the people are the organization’s prized asset and their wellbeing is of paramount importance. - Proportionality: Is the importance of the measurement proportionate to the effort required? We say ‘yes’ as the measurement requires zero effort from the participant. - Subsidiarity: Can the same result be achieved with different means? Our answer is ‘no’ to this question. It is not possible to provide the same depth of insight, reliability and frequency with other available tools. KeenCorp’s compliance has been tested by leading internal law firm Clifford Chance. The executive summary of their legal assessment is available on the KeenCorp website. Also, and equally importantly, KeenCorp’s Privacy by Design recognizes that you may have concerns and questions about your digital communication footprint, visibility and the access by others. In short, you have good reason to have genuine questions. That is why we have visited every team’s meeting to explain about our use of the KeenCorp Index, particularly around these three aspects: - Transparency – we have communicated clearly about what we do. - Clarity of purpose – we have communicated clearly about why we are doing it. - What’s in it for me? We aim to ensure that the benefits for participants far outweighs the perceived ‘costs’ of the algorithm analyzing their digital communication. In this phase, we take time to listen to concerns from all stakeholders and explain as well as we can.

We believe that the software is a useful additional tool to connect with all employees. There are clear advantages for the participants whose emails and communication contribute to the KeenCorp Index scores. The value for you can be defined as follows: - The software creates continuous feedback into management and leadership on how people are doing. And the feedback is by definition a group voice, not a single voice. So, it needs to be listened to. It can’t be ignored. - It is first-hand, can’t be faked and is therefore always reliable. Again, it can’t be ignored. - The people element of the company is truly on the map. There is clear accountability with leadership to improve when and where people are not doing well or are becoming dis-engaged. - There is no “feedback risk” for you: the system is fully anonymous. No content is ever stored and scores can never be traced back to individuals. It is automatic: It requires no extra work, it doesn’t take up any time and there will be no ‘survey-fatigue’.