Privacy & data
What In-Time records about you, who can see it, and how long it is kept.
Staff privacy notice
In-Time is ACT’s internal time-tracking, leave and staff-records app, operated by ACT for project resourcing, fee management, working-time and leave administration, and for holding the studio’s policy documents. This notice describes the personal data it holds about you as a member of staff.
In-Time is offered to ACT staff as part of their employment, not as a service to the public, so it has no separate terms of use. This notice, alongside your contract and ACT’s own policies, is what governs its use, and the app’s Microsoft Teams listing links here for both.
What is recorded
- Your account: name, work email, app role (staff/project leader/admin), studio role (Project Team Member, Intern and so on), weekly capacity. Sign-in is through your ACT Microsoft account, and In-Time never sees or stores a password.
- Time entries: project, phase, date, hours, and any note you write.
- Leave: annual leave requests (dates, half days, any note you add), the decision on each request (who decided, when, and any decision note), and your computed balance. Public holidays and office closures are studio-wide dates, not personal data.
- Commercial figures: fees, budgets and hourly rates belong to projects, not to people. No salary, pay rate or cost figure for any individual is held in this app. Until August 2026 one was, for project costing; it has been removed along with everything derived from it, and nothing in In-Time is now calculated from what anyone is paid.
- Time away: days you were not working and did not book as leave, recorded by you from your own timesheet so the week adds up and nobody chases you for a gap. Each carries the dates, whether it was a half day, and one reason from a fixed list (sick, medical appointment, bereavement, force majeure, other). Nothing else. There is no free-text box on these records, and In-Time never holds a certificate, a diagnosis or any detail of a condition. See Sickness and health-related absence below.
- Studio documents: the employee manual, studio policies and notices, each held as a file with a version and a date, together with a record of which version you have read and when. Your contract and personal employment papers are not held in In-Time. This part is not yet built either.
Who sees what
- All staff see names, projects and phases, their own time entries, leave and time away, the current studio documents, and the dates only of colleagues’ approved leave and time away (never the type, reason or notes).
- Project leaders and admins additionally see everyone’s time entries, project budgets and fees, and thedates of pending leave requests (never the type or note).
- Admins only see leave entitlements and balances, see the reason on a time-away record and the per-person totals at the end of the year, see who has acknowledged which studio document, decide leave requests, and can export CSVs.
Sickness and health-related absence
A record that you were off sick says something about your health, which the law treats more carefully than the rest of what is here. In-Time holds it because ACT has to keep a record of statutory sick leave and of working time, and because those records previously sat in a separate HR system that is being retired. It is held on the basis that ACT needs it to meet its obligations as an employer, not on the basis of your consent: you are not asked to agree to it, and nothing you agree or decline changes your position at work.
What is held is deliberately the minimum: the dates, whether it was a half day, and one reason chosen from a fixed list. There is no free-text box on these records, no certificate is uploaded, and nobody records a diagnosis, a symptom or a cause. Colleagues see only that you were away and when, exactly as they do for annual leave. The reason is visible to you and to the directors, and to nobody else.
You record these yourself, and you can correct them yourself. If you pick the wrong reason or record a day by mistake, you can change or delete it from your own timesheet, and In-Time keeps no history of what it said before. Days away are counted per person at the end of the year so the directors can see the studio’s totals. The app calculates no sick-pay entitlement, and makes no decision about you.
Recording time away was added on 18 August 2026 and came into use on 21 August 2026, the day the directors adopted this notice.
Messages In-Time sends you
In-Time contacts you outside the app in three situations, so that something waiting on you does not sit unnoticed:
- You request leave — the admins who handle requests are told, by a Microsoft Teams alert and an email.
- Your request is decided — you are told, by a Teams alert and an email.
- Your timesheet is behind at the end of the week — you are told, by a Teams alert only. Nobody else is told, and nobody is reminded about a week they spent on leave, a public holiday or an office closure.
What those messages contain is deliberately narrow: the person’s name, the dates, the number of working days, and the outcome. They never carry the leave type, your note, the decision note, or your balance. Those stay inside the app, behind the visibility rules above, because a message travels further than a page does and is harder to take back. Time away sends nothing at all: there is nobody to notify, since it is a record rather than a request, and a message announcing that someone is off sick is exactly the kind of thing that should never leave the page.
Messages are sent through ACT’s own Microsoft 365: Teams alerts appear in your Activity feed, and emails come from an unmonitored ACT no-reply address. Nothing is sent through an external messaging or email provider. Admins can switch off the leave-request alerts they receive; timesheet reminders are a studio-wide setting rather than an individual one; and a decision on your own request is always sent to you, since it is the answer to something you asked.
Email notices have been sent since 21 August 2026, and Teams activity-feed notifications since 11 September 2026. A Teams alert reaches you only if In-Time is installed in your Teams.
Why it is collected
Staffing and resourcing projects, tracking effort against fees, administering working time and leave, keeping the record of statutory sick leave that an employer is required to keep, and making sure everyone can find the studio’s policies and knows which version applies. These are records ACT needs to run the practice and to meet employment-law duties. In-Time makes no automated decisions about you.
Where it lives
The database is hosted by Supabase in Zurich, Switzerland (a country the EU recognises as providing adequate data protection); the app runs on Railway in Amsterdam. Sign-in uses Microsoft Entra ID, and the messages described above are carried by ACT’s own Microsoft 365 — Teams and Exchange Online — which already holds your mail and calendar. These providers process data on ACT’s behalf. Whether the database should move to an EU-member region is under review with IT.
How long, and your rights
Retention periods are in the policy below. You can ask to see, correct, or (where the law allows) delete your data — speak to any director. Nothing in In-Time is shared outside ACT and its hosting providers.
Data retention policy
This policy covers the records In-Time holds. There is currently no wider IT records policy; this stands alone until one exists.
Retention periods
- Time entries and leave records (requests, decisions, entitlements): kept for the year they relate to plus 6 further years, then deleted. Irish working-time law requires at least 3 years; 6 aligns with the Revenue and legal-limitation horizon and preserves effort-vs-fee history while it still has business value.
- The reason on a time-away record: kept for 4 years from the end of the leave year it falls in, then removed, which is the statutory sick-leave record-keeping period. This is deliberately shorter than the rule above, because a health-related record should not sit for six years merely because the rest of the timesheet does. Only the reason is removed; the dates stay on the ordinary leave horizon, as an absence with no stated cause.
- Studio documents and acknowledgements: each version of a manual or policy is kept while it is current and for 6 years after it is superseded, together with the record of who acknowledged it and when. The point of the record is to show what applied at a given time, so it outlives the version it describes.
- Accounts: deactivated when someone leaves ACT (sign-in stops; records stay attributed). Once all of a person’s records have passed the 6-year horizon, their identifying details are removed.
- Project and financial records (projects, phases, fees, budgets): business records, kept indefinitely; they are not personal data once individual identifiers age out.
How it is enforced
Nothing is deleted automatically today. An admin reviews the records each January and removes anything past its horizon. If the studio grows, this becomes an automated job — until then the manual review is the mechanism, and this policy is the instruction to do it.
Sickness records
These used to sit in a separate HR system. That system is being retired, so In-Time becomes their home: the dates, the half-day flag, and one reason from a fixed list. Nothing further. Certificates stay with payroll and are never uploaded here, and the app calculates no sick-pay entitlement. The four-year rule above applies to the reason, and these records are reviewed in the same January pass as everything else.
Status
Drafted 19 July 2026. Revised 18 August 2026 to cover time away (including sickness) and studio documents. Adopted by the directors on 21 August 2026 (decision D26), with one correction: the leave record covers annual leave only, as the app has no unpaid-leave option. Any later change to this notice will be dated here.
Revised 27 August 2026 (decision D47): individual salary and cost figures were removed from the app, and this notice now says so. That is a reduction in the personal data held, and it changes the wording adopted under D26, so it was put back to the directors: re-adopted by them on 27 August 2026.
Corrected 27 August 2026: the example studio roles above were “Architect, Snr PM”, neither of which exists since the directors settled a five-role list on the same day. They are examples only — what is recorded about you is unchanged.
v1.8.0