Privacy policy

Who is responsible for what

An audit is run by a firm (or a company) that decides why and how data is processed: together with the audited company, it is the data controller. Trustelia provides the platform as a processor, under a processing agreement (GDPR article 28) and following the controller’s instructions.

The legal basis of an audit is therefore set by the controller. The product is designed around the employer’s legitimate interest rather than consent, which is considered fragile between an employee and their employer; the interview’s welcome screen informs you, it does not replace that basis. The documents of each engagement (information note, works-council kit, impact-assessment template) are supplied by the platform to the firm.

For platform users’ accounts (consultants, sponsors, administrators), Trustelia acts as controller for the data strictly needed for account access and security: name, email, role, sign-in logs, two-factor authentication.

Data captured during an interview

The AI never pretends to be human: you are told from the invitation and on the welcome screen. Nothing is captured outside an open session, and no software is installed on your computer.

• Your voice, during the interview, streamed in real time to the AI that conducts it.
• The content of your screen, if you choose to share it: a few images per minute, analysed by the AI, and a video recording if the engagement provides for it. You can stop sharing, show a single window or mask an area at any time.
• The transcript of what is said, and the recap of each chapter, which you validate, correct or remove point by point.
• Documents that you or the firm upload (documents, pinned captures).
• Your name, email address, role in the company and your interview settings. In the deliverable, statements are attributed by role, not by name, by default.

What we do not do

• We assess processes, never people: no mark, score, ranking or individual comparison, in the interface, in the exports or in the chat.
• No analysis of emotions: no tone, stress or hesitation. The AI analyses what is said and shown, not how it is said.
• The sponsor (the commissioning person in the company) never sees the raw recordings.
• No data is sold, or used for advertising or to train models of our own.

AI providers and other processors

The platform is provider-agnostic: voice, transcription, vision, analysis and chat are set separately. By default, these uses are provided by OpenAI. The firm may choose other providers from the platform catalogue: Mistral AI, ElevenLabs, Deepgram, Anthropic or an OpenAI-compatible provider; the list used for an engagement appears in that engagement’s compliance documents. Reading the text in images, used to blur sensitive data, runs on our own servers, with no external call.

Providers receive the data strictly needed for their service (for example the audio stream for voice, already-blurred images for vision) through their professional interfaces. For OpenAI, used through its API: according to its public policy, data sent through the API is not used to train its models, and requests are kept at most 30 days to detect abuse. For the other providers the firm may enable, the chosen provider’s terms apply; the firm knows them and the engagement lists them.

Blurring of sensitive data

Before a screen image leaves for an AI provider, and before a video can be seen by a person, recognised sensitive data (IBANs, bank cards, social security numbers, third parties’ emails and phone numbers, password fields) is blurred, as are the areas you mask yourself. No detection is perfect, especially for handwriting: that is why you are reminded not to show third-party data.

Retention periods

Periods are set by the firm for each engagement. By default:

• Raw recordings (audio, video, screen images): 90 days after the session ends, then deleted. A warning is sent to the firm 7 days before.
• Transcript, recaps, published evidence and deliverable: kept longer, 730 days by default after the engagement is archived, then deleted.
• Generated exports: 7 days.
• Access log of the recordings (who listened to what): 3 years.
• Interview link: valid until the engagement deadline plus 30 days, or 90 days by default, and revocable.
• Immediate removal: what you remove from a recap or a deleted passage also disappears from the analysis, the evidence, the deliverable and the search index.

Your rights, and how to exercise them

You have the rights of access, rectification, erasure, restriction, portability and objection. As the controller is the firm or company that invited you, address them to it first; if you write to us (contact@mankova-consulting.com), we forward your request without delay and do not answer in its place.

The platform makes these rights easier: from your link you see everything that concerns you, you correct or remove recap points, and the firm can delete your whole interview in cascade with one click. You may also contact the CNIL or your country’s supervisory authority.

Transfers outside the European Union

Hosting is in France. The default AI providers (OpenAI) are established in the United States: some data is therefore transferred there. It is covered by the EU–US Data Privacy Framework and by the European Commission’s standard contractual clauses. For another provider outside the Union, the firm finds the applicable mechanism in the engagement’s documents. The firm may prefer a European provider; each one’s location is shown in the platform configuration and in the engagement’s documents.

Security

• Encryption in transit and at rest; random, time-limited and revocable interview links.
• Workspaces isolated per firm, two-factor authentication mandatory for administrators.
• Access to recordings is logged; Trustelia’s team only accesses them with the firm’s express authorisation, stating a reason.

Platform cookies

Workspaces and interviews only use strictly necessary cookies, described in the cookie policy. No audience measurement or advertising is loaded there.

See also : Cookies