This wording is prepared for the law of Ireland (the GDPR and the Data Protection Act 2018). Last updated 8 October 2026.

Privacy notice

A line manager or buddy without a work inbox will soon be able to get their check-ins by WhatsApp instead of email.

This notice explains how Accolgo handles your personal data under the GDPR and Ireland’s Data Protection Act 2018. Accolgo is an early-warning system for the first months of a new job. It asks a new starter, their line manager and a buddy short check-in questions and turns the answers into a colour and a suggested next step for the line manager, without anyone reading the individual answers so that a supportive conversation happens at the right moment.

Accolgo’s colour, reasons and suggested next step are there to prompt a supportive conversation, not to judge anyone’s performance.

Who is responsible for your data

Your employer (the organisation that invited you) decides why and how your check-in data is used, so it is the controller. Accolgo processes that data on the employer’s documented instructions as its processor. Questions about your data should go first to your organisation’s people team; you can also contact Accolgo directly. Where your employer has appointed a data protection officer, they are your first port of call.

Clickonic Limited is registered with the Information Commissioner’s Office, registration number ZA751171.

What we collect

Your name, work email, job title, start date and who your manager and buddy are.
Your check-in answers: worded replies to short questions.
Your notes and requests: an optional note to your manager, and an optional request for a conversation.
From managers and buddies: their check-in answers about how the starter seems.
Follow-up records: that a manager marked a conversation as done, with an optional short note.
Once WhatsApp check-ins start, which is coming soon, from a line manager or buddy who chooses WhatsApp: their mobile phone number, so that their check-in can be sent to it.

Health and other sensitive information

Some check-in questions ask how you are feeling and settling in. Your answers, and anything you choose to write in a note, may tell us something about your health, including your mental health, or about something that has happened to you at work, such as harassment. The law calls this “special category” information and gives it extra protection. We do not ask you for it directly, but you may choose to share it, and we treat everything you write as if it could be.

When a note may mean you, or someone else, is at risk. Accolgo’s software reads each note for words that suggest a risk of harm, sexual harassment, bullying, or another safety concern. If it finds them, it marks the note with that type of concern and sends it straight away to the senior people your employer has named to handle this (usually the head of people). It may also show you details of a free helpline.

A note you write for your manager is read by your manager. Your head of people sees it only if your next check-in is still not settling. When Accolgo picks up a safety concern in a note, it also goes to HR. If our software thinks the note may show a concern, we will ask you whether it is about your manager. If you say yes, your manager will not see it and only the senior people will. A private word with someone senior, or a note you have said is about your manager, goes to your manager only if your organisation has nobody senior other than your manager, and you are told this before you send it.

The software can be wrong in both directions: it can mark something that was not a concern, and it can miss something that was. The software never makes a decision about your job, pay, probation or performance. It only decides who is shown a note and what marking appears; a person at your employer reads it and decides what happens.

Who decides the rules. Your employer decides whether to use Accolgo and who receives these notes, and is responsible for the legal reasons for handling this information. Accolgo designs the word checks and the categories. You can ask your employer which legal reasons it relies on (see below).

How long it is kept. A note that raised a concern is kept while the concern is open, even if it would otherwise have been deleted, so that nothing is lost while it is being dealt with. After that it follows the normal schedule in our data retention policy.

Your choice. You never have to write a note. If you would rather speak to someone in person, you can ask for a word with your manager, or a private word with someone senior who is not your manager.

Our lawful basis

Your employer is responsible for choosing the legal reasons for using your information, and must be able to tell you what they are.

For ordinary check-in information, most employers rely on legitimate interests under Article 6(1)(f) of the GDPR: keeping new employees supported and reducing avoidable early leaving, balanced against your interests and rights. Your employer should keep a record of that balance, and you can ask to see it.

For health and other special category information, the law also requires a condition under Article 9. Most employers can rely on the employment condition in Article 9(2)(b) only where the processing is necessary for a legal duty, such as preventing harassment or protecting health and safety at work. Your employer must record why that applies and keep an appropriate policy document. Your employer may choose a different condition; if so, it must tell you which. We ask every employer to confirm its choice before its people start using Accolgo.

Who sees your answers

Nobody at your organisation reads your individual answers: not your manager, not the head of people and not anyone in HR. Accolgo’s software turns your answers into a colour, the reasons behind it and a suggested next step for your manager. Your answers are stored in our database. Our database provider (Supabase) encrypts everything it stores at rest; Accolgo does not add separate encryption of its own. Access to the stored data is limited to the Accolgo application itself and Accolgo’s own authorised technical staff, who need it to run the service, not to read your answers, and to Supabase as the provider that hosts it. A note you choose to write to your manager is read by your manager. If your next check-in is still not settling, your head of people sees that note too, with your manager’s follow-up notes. When Accolgo picks up a safety concern in a note, it also goes to HR, or to HR alone if it is about your manager. A private word with someone senior goes to the head of people and any named senior contacts your organisation has set up, as described below.

In rare cases, such as a legal requirement or a serious safety concern, a starter’s answers can be released to their employer, only on a written request approved by Accolgo, and never routinely.

Markings, not verdicts. Accolgo turns each check-in into simple scores by topic (1 to 5), and uses them to give each new starter one of four markings: Needs attention, Worth watching, Settling well, or Too early to tell. The marking is a prompt for your manager to have a conversation, not a judgement about you or your performance. It is never used to rank people against each other and there are no league tables of people. The software never makes a decision about your job, pay, probation or performance. It only decides who is shown a note and what marking appears; a person at your employer reads it and decides what happens. You can ask to see your markings and scores as part of a subject access request.

What we never do

No automated decision-making producing legal or similarly significant effects under Article 22 of the GDPR. Every decision about a person is taken by a human at your employer.
A “private word” with someone senior who is not your manager goes to the head of people and to any named senior contacts your organisation has set up. It never goes to your manager, except when your organisation has nobody senior other than your manager, in which case you are told this before you send it and shown other sources of help. Where it does not go to your manager, the head of people decides whether, and when, your manager is told. It is stored in the database along with other check-in answers, and access to that stored data is restricted to Accolgo's own authorised technical staff, who need it to run the service.
No selling of data, no advertising, no profiling beyond the check-in signal itself.
Nothing is collected covertly: every check-in is asked for openly, by email and, soon, for a line manager or buddy without a work inbox, by WhatsApp, and this notice is shown before the first one.

Your rights

You have the right to be informed, to access your data, to have inaccurate data corrected, to erasure, to restrict or object to processing, and to data portability. A subject access request includes what your manager and buddy said about you, balanced against their rights as the law requires, and must be answered within one month. Requests go to your organisation’s people team or to Accolgo.

If you believe your data has been mishandled you can complain to the Data Protection Commission, the Irish supervisory authority. We would ask that you raise it with us or your employer first so we can put it right.

If you contact us through our website

If you use the enquiry form on our website, we collect your name, work email, organisation, roughly how many new starters you take on a year and anything you write in your message. We use these details only to reply to your enquiry. They are sent to us by email through our email provider and are not saved in the Accolgo database. For these details, Clickonic Limited (Accolgo is its trading name) decides how they are used. We keep the email for as long as we need it to deal with your enquiry and anything that follows from it.

Cookies and website analytics

Accolgo sets essential cookies to keep you signed in and to remember your cookie choice. These do not need your consent.

If you accept analytics cookies, we use Google Analytics to learn how people use our website and the Accolgo app, so we can improve them. It records which pages are opened and which features are used, such as running the calculator, starting the product tour or adding a new starter. For signed-in users it also records their kind of role (for example line manager or head of people) and which country's version of the site they use.

It never records names, email addresses, organisation names, check-in answers or anything anyone types, and page addresses are recorded without any record number in them. Google Analytics is never used on the check-in pages that new starters, managers and buddies answer, on unsubscribe pages or in emails.

Google Analytics sets cookies whose names begin with _ga. They last up to six months. Google's advertising features are switched off, so nothing collected is used for advertising. Google Analytics keeps this data for 14 months and then deletes it.

For this analytics data, Accolgo decides how this data is used. Accolgo is a trading name of Clickonic Limited. We rely on your consent for these cookies and for the analytics they make possible. Google may process this data in the United States and other countries. Transfers outside the European Economic Area are made under the safeguards described under where data lives.

You choose whether to accept or reject analytics cookies when you first visit. You can change your choice at any time using the Cookie settings link at the foot of the page. If you withdraw your consent, analytics stops straight away and we remove the Google Analytics cookies from your browser. We ask again after six months.

Contact us

For anything about your personal data, including asking for a copy of it or making a complaint, email dermot@clickonic.co. We will acknowledge a complaint within 30 days and tell you what we have done about it. You can also contact your employer’s people team, who control your data. If you are still unhappy, you can complain to the Data Protection Commission (dataprotection.ie).

Where data lives, and international transfers

Your check-in data is stored in the United Kingdom, in Supabase’s London region. The European Commission has decided that the United Kingdom protects personal data adequately, so transfers from Ireland to the United Kingdom rely on that adequacy decision. Some processors handle limited data elsewhere: hosting (Vercel), transactional email (Resend) and the in-app help assistant (Anthropic) may process it in the United States, and error monitoring (Sentry) in the United States or the EU.

Transfers to the United States are made either to organisations participating in the EU-US Data Privacy Framework, which the European Commission has decided is adequate, or under the EU standard contractual clauses together with a transfer risk assessment. Our processors are hosting (Vercel), database and authentication (Supabase), transactional email (Resend), error monitoring (Sentry), the in-app help assistant (Anthropic) and payments by your employer (Stripe, which never sees your check-ins). Each is bound by a written processor agreement.

Once WhatsApp check-ins start, which is coming soon, and a line manager or buddy chooses WhatsApp, their check-in message will be sent through Twilio, and Meta will provide the WhatsApp Business service that carries it. Twilio and Meta will handle their mobile phone number and the message, which can name the new starter and holds a private check-in link.

How long we keep it

We intend to keep personal data only for as long as the onboarding programme needs it, and then delete it on the schedule in our data retention policy. Automatic deletion is not switched on yet. Until it is, we keep personal data until it is deleted, and we delete it by hand when your organisation asks or you exercise your right to erasure, save for anything the law requires us to keep. The retention page has the dated update.

Anonymised history, which no longer identifies anyone, is intended to be deleted once it is more than 3 years old, once automatic deletion is switched on.