The goal of 360° Feedback is to support individuals in prioritizing and planning their personal development. To support this, Finastra uses your data in several ways. This policy is to help you understand:

• How we use your data


• Who we share your data with


• Your rights to your data


• How we delete data.


• How we use your data

• Match your payment to your assessment


• Provide you with access to choose feedback providers on Spidergap.com


• Just so you know, your contact details (not including credit card information), may be transferred unencrypted and involve (a) transmissions over various networks; and (b) changes to conform and adapt to the technical requirements of connecting networks or devices.

• Create individual feedback reports that aggregate the feedback collected about an employee being assessed. Except for the self-assessment and line manager’s feedback, feedback will be anonymized by combining it with the feedback given by others. Text responses will be unaltered and may be identifiable from the language r feedback given.


• Review group results to identify trends and perform a Training Needs Analysis (TNA). All feedback will be anonymized by combining responses. Text responses will be updated to remove any names used and may be updated to emphasize key points. Text responses may still be identifiable from the language used or feedback given.


• Screen for and remove any undesirable or abusive feedback.

• The individual feedback report with the person assessed


• The individual feedback report with a coach of the person assessed


• Aggregated and anonymized group reports with Finastra team members to help us review trends and identify opportunities to improve how we support personal development at a group level


• Individual responses with project administrators to provide support, review group results, and to screen for abusive feedback. Only staff from Finastra will be given project administrator access. You may request an up-to-date list of who has access by emailing leading@finastra.com


• Your data with our service provider. We use Spidergap — a third-party service — to support the 360° Feedback process. We have reviewed that Spidergap meets our standards and legal requirements for data protection and will monitor to make sure it continues to do so.


• Your credit card information with Stripe, our payment processor. Credit card information is always encrypted during transfer over networks. We do not store or process credit card details — Stripe, a secure and PCI-accredited third party, processes these. 

• You may request access to or deletion of your data at any time by emailing leading@finastra.com


• You agree that you are not to reproduce, duplicate, copy, sell, resell or exploit any portion of the Service, use of the Service, or access to the Service or any contact on the website through which the Service is provided without express written permission by us.

• We will delete data about a person being assessed upon their written request. The data may remain in backup systems for up to 12 months after it is deleted.