Equity Clear Pilot:
Data Handling, Access and Retention Policy
1. Purpose
Equity Clear collects a limited set of information from participating organisations to understand how companies progress through the startup funding pipeline.
We recognise that this information is commercially sensitive. Taken together, it can reveal which companies have approached a particular investor, how far they progressed through that investor’s pipeline and whether funding was provided.
This policy explains how data submitted during the Equity Clear Pilot is handled, who can access it and how long it is kept.
Our approach is based on three principles:
collect and retain only what is needed;
restrict access to the minimum necessary; and
protect the confidentiality of each participant’s pipeline.
The longer-term national reporting framework will have its own retention arrangements. Before national reporting begins, Equity Clear will determine what information needs to be retained to support ongoing reporting and company matching, how long it should be kept, and who may access it.
2. What information is submitted
Participants submit a defined set of company and pipeline information, including company name, website, application received (month/year), location, sector, founding-team gender category, stages reached, funding outcome and, where applicable, amount funded.
3. Why we collect company names and websites
Company names and websites are needed so the platform can recognise when the same company appears more than once.
This allows us to reduce double counting, match records across the Pilot reporting periods and improve the accuracy of the resulting data.
Company identifiers are treated as protected information. The platform separates direct company identifiers from the data used for analysis and reporting and uses protected company identifiers for those purposes.
4. Who can access the data
Participants can access only their own organisation’s submissions and analytics. They cannot see another participant’s pipeline, submissions or matching information.
mnAI, as the platform provider, may access submitted data where required to operate, maintain, secure and support the platform, including processing submissions and performing company matching. Access is limited to authorised personnel.
Equity Clear may access de-identified reporting data after it has been processed by the platform to remove participant and company identifiers, for the purposes of analysing and evaluating the Pilot.
During the Pilot, Equity Clear may also receive company names and websites without information identifying the participant that submitted them, for the limited purpose of reviewing how accurately the platform is matching companies and identifying data-quality issues.
UNSW Centre for Social Impact acts as Equity Clear's Research Advisory Partner. UNSW will not receive identifiable participant pipeline data as part of its ordinary research advisory role. If human review of company matching or another data-quality issue is required during the Pilot, Equity Clear may appoint a specifically authorised UNSW representative to undertake that review. Any access will be limited to the information needed for that purpose and provided through an approved, secure and audited process.
No Participant will have access to another Participant's identifiable pipeline data.
5. How long data is kept
We keep Pilot data only for as long as it is needed to operate, validate and evaluate the Pilot, subject to the retention arrangements below.
Original upload files are kept only for the period needed to process and validate a submission and resolve any corrections or support issues. Approved or replaced upload files are scheduled for secure deletion 90 days after approval, unless they are still required for an open correction, investigation or legal requirement.
Temporary validation data is deleted after approval and the applicable correction period.
Reporting data stored in the platform is retained for the duration of the Pilot platform services to support reporting and analysis during the Pilot. Company matching information and audit history are retained with the corresponding reporting records.
Backups and application and security logs are retained in accordance with the applicable approved retention settings.
Equity Clear may retain and use aggregated or de-identified information from the Pilot where individual companies, founders or participant pipelines cannot reasonably be identified. This may include using high-level findings to evaluate the Pilot, improve the reporting framework and communicate what we have learned.
6. Future use and longitudinal analysis
The Pilot uses company matching to support accurate reporting, reduce double counting and recognise records across Pilot reporting periods.
The same capability could, in future, support analysis of how companies progress through different parts of the funding ecosystem over time.
Broader longitudinal analysis is not part of the Pilot. Before introducing this as part of the national reporting framework, Equity Clear will consult with participants and consider the appropriate privacy, governance and data-access arrangements. Participants will be informed of the approach before it is implemented.
The system is designed around companies, not individual founders. Equity Clear is not creating profiles to track individual founders across different companies.
7. Security and confidentiality
The platform is required to keep identifiable Pilot data stored, processed and accessed in Australia. Production use of identifiable data is subject to approval of the relevant hosting, backup, logging, support-access and subprocessor arrangements.
Access is role-based and restricted according to operational need. Participants are technically separated so that one participant cannot access another participant’s submissions or results.
Company matching must not reveal whether another participant has submitted the same company. Reporting is also subject to controls designed to prevent companies, founders or individual participants being identified from small or highly specific groups of data.
The MVP specification requires encryption, server-side access controls, tenant isolation, audit logging and separation of direct identifiers from analytics data.
8. Review after the Pilot
This policy applies to the Equity Clear Pilot.
As part of the design of the national reporting framework, Equity Clear will review the longer-term arrangements for company matching, data retention and access.
This may include appointing a small number of specifically authorised personnel to resolve company matching and data-quality issues. Any such access would be limited to what is necessary for that function and subject to appropriate access, confidentiality and audit controls.
Equity Clear Pilot: Data Handing, Access & Retention Policy, Version 1.0 | Effective: 8 October 2026