Privacy in WellKey
WellKey does not ask employees for a name, email or phone number. Conversations and answers are private, and the organization has no access to them. HR sees only group results, from 10 answers. We do not promise that in a small team nobody can ever guess who answered. That is why we use a threshold and do not show results of small groups.
What HR sees and does not
| HR sees | HR does not see |
|---|---|
|
|
What we collect and why
| What | Why |
|---|---|
| Login data: a login code and a password stored as a hash | So an employee can return to their account without giving a name, email or phone number. |
| Check-in answers | The aggregated team result is built from them. The result comes only from check-in answers, not from the content of conversations with the assistant. |
| Conversations with the assistant, notes and habits | So the employee can come back to them. They are private and the organization has no access to them. |
| Team membership | So a result can be shown for a group, and only once the group reaches the threshold of 10 answers. |
When someone writes about a crisis
When crisis language appears in a conversation, the assistant does not reply with model-written text. It shows a fixed, pre-written response with help numbers. WellKey is not an emergency service, and it does not diagnose, treat or replace a psychologist.
Data protection impact assessment
Data protection impact assessment (DPIA): in preparation, together with a lawyer. We will share it with companies before the pilot starts.
Security basics
- Connections over HTTPS, with the HSTS header
- Signed session cookies
- Role-based access
- Passwords stored as a hash, never as plain text
Processors
- Data is stored and processed in the EU (Ireland).
- The assistant uses Google Gemini on a paid plan: Google is our processor, does not use conversations to train models, and receives the conversation text without names or company data. Google may process data briefly outside the EU, under standard contractual clauses.
Deleting an account
An employee can delete their account and private data in the app.