This policy explains how we process personal data within our global businesses delivering search, consulting and assessment services, including how it affects our websites: www.odgersberndtson.dk, www.pointersearch.dk, www.odgersinterim.com
Who we are
Odgers Berndtson P/S and Pointer A/S work closely together and we have a need to share Personal Data to help us run and provide our executive search services or assessment services. We have therefore entered into an agreement regarding joint data control. Odgers Berndtson P/S and Pointer A/S are hereinafter jointly defined as “Odgers Berndtson Denmark”, "we", "us", “our”. We represent the global businesses that trade as Odgers Berndtson P/S, Pointer A/S and Odgers Interim. Details of Odgers Berndtson firms are set out at the end of this policy document. Further information about our firm and our global offices can be found by clicking here.
Odgers Berndtson Denmark is committed to keeping your information secure and managing it in accordance with our legal responsibilities, under the privacy and data protection laws applicable wherever we operate in the world, as well as the General Data Protection Regulation (Regulation (EC) 2016/679 (“GDPR”) in the European Union (“EU”).
Our standards exceed those of the Association of Executive Search and Leadership Consultants, of which we are a member.
This policy was last updated in August 2023. Please review this policy periodically for any changes.
Who this policy applies to
We provide executive search, assessment and leadership services and the provision of interim managers (“our services”) to a range of clients throughout the world. Details of our services can be found elsewhere on this website or those listed above. This policy applies to you whether you are a candidate for one of our clients, an individual we are assessing as an employee of one of our clients, a client or whether you are a source or a referee in respect of a candidate or an employee of one of our clients.
Additionally, this policy will apply to you if you attend one of our events or have subscribed to receive information about our services or any of our marketing materials such as our regular newsletter OBSERVE.
For the purposes of this policy:
candidate(s) means an individual who is a candidate, applicant, potential candidate, employee of a client;
client(s) means any, business, firm, organisation, government body or individual that mandates us to perform any of our services;
referee is a person who provides a personal or work reference in respect of a candidate and;
source is a person who provides us with information or intelligence about a candidate.
Our clients expect that we identify the best individuals to fill roles within their organisations. So, we need to research systems, online databases and other information sources, and talk to many individuals. Besides our clients, these will include referees and sources to help inform our decision-making process.
The nature of our work means we are required to process personal data quickly, confidentially and often without reference to the data subject. Accordingly, we process such data in accordance with the Data Protection Laws, regularly using our legitimate interest where it is not possible or feasible to speak directly with the data subject. Beyond this, we will seek consent in the circumstances explained later in this policy document.
We collect information from candidates directly when you upload send us your CV or resume via email or post. We also collect information from you when you speak with an Odgers Berndtson Denmark employee in any office around the world.
How we use your personal data
We use the personal data we collect from you for a number of purposes:
- Processing job applications, in partnership with our clients, on whose behalf we are instructed to help fill a job vacancy. This means that if you apply for a specific job, we may pass your details to the relevant client to proceed with the application. As a result, you may receive further direct correspondence from them.
- Searching for relevant candidates for confidential recruitment assignments where our client is not initially named. This means that if we believe you are suitable for a specific role, we may pass your basic details on to the relevant client. If that client agrees that you might be suitable, we will then discuss this with you in more detail. You might be interviewed for the role by one of our consultants. If successful, you might be shortlisted for interview by our client. At this point, we will pass further details to the client and you may receive further direct correspondence from them.
- From time to time, we conduct mapping or research exercises on behalf of our clients. This is to enable them to understand a particular market. Here, we may include certain aspects of your personal data. You will not be contacted by any third party about this unless we first obtain your consent.
- For the performance of a contract, we have concluded with you as an individual, most likely an assessment or coaching programme.
- For equality monitoring purposes, to understand the diversity of our applicant pool, but only if admissible under the applicable law. (This information is anonymised and aggregated).
- Improving the services we offer. For example, you may be asked to complete one of our online satisfaction surveys.
- For marketing purposes to send you information on our services, white papers, newsletters, events and so forth. Please note you may opt out from receipt of marketing materials at any time by writing to us.
We will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others or, have your permission to do so.
Please be aware that we are not responsible for the data processing activities of others, such as our clients.
We will use client data to perform our services to you and other legitimate business purposes such as marketing.
We will use source and referee data to perform our services, in particular to enable us to obtain your opinions on a candidate.
We may also use this information to enable us to market our services to you as a potential client. We may as well invite you to become a candidate in respect of the provision of our services.
The type of personal data we collect and process
In all cases we collect and process personal data about you, including your name, address, telephone number and email address.
We will as basis seek specific consent when processing Personal Data as part of our work with Executive Recruitment and Assessment and Leadership Services, in accordance with the GDPR article 6(1)(a). We will therefore not collect Personal Data from you unless you have specifically agreed to us doing so through a GDPR compliant consent form when you submit a resume to us either in hard copy, via e-mail or by other means. The consent is sent via an electronic channel.
We might also collect personal data from third-party databases and other public sources. Our legal basis for this is our legitimate interest according to GDPR article 6(1)(f) by potentially matching you with a suitable position.
Candidate to a specific position
If you proceed with a job application, or should we consult you about a role, you may be required to submit additional personal data. For example, date of birth, education and career history and curriculum vitae (CV), or resume. Your CV or resume may contain employment history, education, professional qualifications, memberships, details of papers written, amongst other things. For such processing Odergers Berndtson Denmark will be data processor on behalf of our client. If we collect references and referees we will – on behalf of our client – collect your explicit consent according to the GDPR art. 6(1)(a).
Based on your explicit consent (according to the GDPR art. 6(1)(a) and art. 9(2)(a), we will also process any relevant psychometric assessments, psychological tests, or results from such assessments or tests.
As well as basic contact information we will also collect information about your role and other information provided to us by your organisation.
As well as basic contact information we will also collect information regarding your credentials as a source, details of your professional relationship / knowledge of a candidate and your opinions of that individual. We may obtain this information directly from you or publicly available information. Prior to such processing we have collected explicit consent – on behalf of our client – from the data subject in question and will present you with this.
What we do
Besides filling particular leadership vacancies, we also process personal data when we conduct market intelligence exercises to map out particular business sectors or functions to help clients understand the available talent.
From time to time, we will seek your consent – on behalf of our client – in accordance with the GDPR article 9(2)(a) to process personal data in respect of certain specific and limited purposes. We will always do this before processing any sensitive personal data. We encourage you not to provide us with sensitive personal data, unless it is specifically requested, and we have your consent.
We may also provide services to our clients in Denmark that entail the assessment and coaching of their employees. Here, depending on the specific assignment, we will either process your personal data to meet the legitimate interests pursued by the client, or act on their behalf, in accordance with their instructions. If our services include any psychometric assessments or psychological tests, and we’re not acting on behalf of your employer, we will – on behalf of our client – obtain your explicit consent in accordance with the GDPR article 6(1)(a) and article 9(2)(a).
In Denmark, we provide services to individuals, such as assessment and coaching. Here, we will process personal data for the performance of the contract with you. If our services include any psychometric assessments or psychological tests, we will obtain your specific consent in accordance with the GDPR article 6(1)(a) and article 9(2)(a).
Your right to object and to have your data erased
You are not obliged to provide any personal data to us. However, please note that this may mean we will not be able to consider you in respect of some of our services.
In these circumstances, we reserve the right to maintain basic personal data such as your name and address. This is to ensure your personal data isn’t processed by us in the future.
Please note that no automated decisions, such as computerised candidate profiling, are made on the basis of the information we collect.
Newsletters and other communications
If you would like to receive one of our newsletters, we will ask you to provide us with your name, email address, job title, company name and country of residence. We will in such case collect your applicable consent in accordance with the GDPR article 6(1)(a) and the Danish Marketing Practices Act section 10.
You can unsubscribe from our electronic marketing messages by following the “unsubscribe” instructions included in our communications. Also, you may change your preferences and cease receiving direct marketing from us through your email account settings.
If you take part in a user satisfaction survey, we may ask you to provide us with personal data, including your name, email address, and your views and opinions. In this regard our processing will be based on your explicit consent in accordance with the GDPR article 6(1)(a).
Providing information to others
To help us run this website, and to provide executive search services or assessment services in Denmark, we work closely with trusted partners with whom we need to share personal data. These partners include:
- Other Odgers Berndtson offices around the world have signed up to an Intra-Group Data Transfer Agreement. This enables us to transfer personal data within our international group.
- Our clients, for whom we provide executive search services.
- Our clients, for whom we provide assessment and coaching of their employees in Denmark.
- Prospective clients, where we might need to demonstrate an understanding of a particular market and the individuals that work within it.
Where we share information with such a third party, you will not be contacted by them, unless we have obtained your prior consent.
We may also provide information to third party service providers who process information on our behalf. This is to help run some of our internal business operations, including email distribution, IT services and customer services. As part of our agreements with them, these third parties are required to process such data securely and only in accordance with our instructions.
Your information may also be shared with organisations located elsewhere in the world. As their privacy laws may not match your home country’s standards, we’ll only make a transfer data if adequate levels of protection are in place to protect any information held in that country, or the local service provider complies with applicable privacy laws at all times.
Where required by law, we will take measures to ensure that personal data handled in other countries will receive at least the same level of protection as in your home country.
We may sometimes be required to disclose information about you to law enforcement bodies, agencies or third parties, under a legal requirement or court order. We will act responsibly and take account, where possible, of your interests when responding to these requests.
If your personal data is transferred to data controllers or data processors which are located in countries outside the EU/EEA, including group entities, not ensuring an adequate level of data protection, such transfer will be safeguarded by the EU Commission’s standard contractual clauses.
We invest significant resources to protect your personal data, from loss, misuse, unauthorised access, modification or disclosure. However, no system can be 100% secure, and so we cannot be held responsible for unauthorised or unintended access that is beyond our reasonable control.
Information about others
Keeping your records
We keep your personal data for as long as required to provide our services, and in accordance with legal, tax and accounting requirements. Where your personal data is no longer required, we will ensure it is disposed of in a secure manner. Where required by law, we will notify you when this has happened.
In Denmark, you may have the right to request copies of your personal data held by us. If you think any of that data is inaccurate, you may also ask us to correct it. You may also have a right, in certain circumstances, to require us to stop processing your personal data. Also, you have the right to ask us to transfer your personal data to someone you nominate for your own purposes.
To get in touch with us about any of this, please email or write to us at the address below. Please note that we may request proof of identity. We will respond to your requests within the time frame that applies in the country concerned.
In certain circumstances, where it is required or permitted by law, we might not be able to provide you with access to some of your personal data. Wherever possible, we will notify you of the reasons for this.
About our websites
We use the personal data we collect from you on our website for additional purposes such as personalising the look and feel of the website to fit the personal preferences inferred from how you’ve used the site. (See the "Analytics" and "Cookies" sections for more information.)
We may disclose or share personal data with third parties as outlined above to operate the website and provide our executive search services, as well as assessment services in Denmark. If you are concerned about these arrangements, you should not use the website and contact us to ask us not to process your personal data.
Updating your account and preferences
If you register an account with us, or with a local partner who provides a job application portal on our behalf, please do keep your details up to date, and notify us of any changes to your personal data. You can do this by updating your user preferences through your account login, or by contacting us using the details below.
Odgers Berndtson is a proud member of the Association of Executive Search and Leadership Consultants
Odgers Berndtson Denmark commits to the AESC Code of Professional Practice and Standards of Excellence.
Odgers Berndtson’s global business is committed to the highest standards of social and environmental responsibility. We expect our suppliers and business partners to share our aim to promote lawful, professional, fair practices that respects human rights, have the highest business ethics and sustainability, and to support and contribute to our aim of maintaining and improving our environmental and social commitments.
We recognise both the opportunity and responsibility we have, in partnership with our suppliers, to take a lead in addressing pressing global issues. Therefore, environmental, social and economic considerations are embedded in our decision-making. This applies to the suppliers we use as well. We believe sustainable procurement will help us achieve sustainable growth by managing risk, maximising efficiency and driving value.
This Supplier Standards of Conduct exists to promote and ensure safe and fair working conditions and the responsible management of environmental and social issues in our supply chain.
We require agreement with these “Standards” from all those involved in our supply chain. The Standards describes our expectations of how all our suppliers conduct their business and applies to all suppliers providing products or services to us. All suppliers are expected to act in accordance with the Standards, including aligning policies, practices and guidelines and communicating and enforcing the Standards throughout their organisation and across their supply chain.
We expect our suppliers to operate in accordance with all applicable laws and regulations. This includes those respecting individuals' human rights, and mindful of environmental and safety impacts of products and services. When differences arise between standards set out in the Standards and legal or regulatory requirements, the stricter standard applies, in compliance with applicable law or regulation.
We're committed to adhering to the following core values in all our dealings with our clients, our people and our communities:
- be supportive;
- be collaborative;
- be fair.
We expect all our suppliers to support these values through the products and services they provide to us.
We recognise our responsibility to protect human rights. We expect our business partners and suppliers to respect human rights and to have in place policies and processes to meet their responsibility to protect and respect human rights that apply to all workers, suppliers, and their supply chains and to comply with all relevant legislation, regulations and directives in countries where they operate.
Suppliers sourcing goods or services in geographies with high risk of human rights violations should notify us immediately and provide information on the steps the supplier has taken to ensure risk of violation of human rights in relation to this purchasing activity are being fully mitigated. Countries with high risk of human rights violations can be identified via public sources.
We have obligations under the The European Convention on Human Rights to ensure compliance and we take this responsibility serviously.
Suppliers and business partners will not use or permit their subcontractor to use child, slave, forced or obligatory labour, including prison labour, indentured labour, bonded labour or other forms of forced labour.
These practices, identified by the International Labour Organization (ILO), include withholding of wages, retention of identity documents, and restriction of movement. For full guidance from the ILO please see: The 8 ILO Fundamental Conventions.
Suppliers should put into place measures that ensure workers are not exploited by third-party labour providers.
Additionally, suppliers must not engage in or support human trafficking and are encouraged to implement due diligence measures to ensure that no human trafficking exists in their extended supply chains. Suppliers must also fully comply with requirements of applicable slavery, forced labour and human trafficking laws without limitation.
Suppliers and business partners will ensure that no person under the age of 15 or under the age for completion of compulsory education, whichever is higher, is employed. The necessary preventive measures to ensure this include age-verification systems, training for managers, and communicating with sub-contractors and suppliers on child labour issues. Suppliers must also comply with local laws regarding the minimum age of employees and all other applicable child labour laws.
Our suppliers must ensure that workers are not required to work more than the relevant legal limits on working hours, overtime hours and number of working days per week. All overtime work must be consensual. Workers must be granted and correctly compensated for any types of paid leave or time off to which they are legally entitled under applicable law, which may include holidays, maternity/parental leave, family care leave and sick leave. While it is understood that overtime may be required, suppliers must carry out operations in ways that limit overtime to a level that ensures humane and productive working conditions
Freedom Of Association And Collective Bargaining
Our suppliers and business partners must recognise and respect the right of employees to freedom of association and collective bargaining without interference, discrimination, retaliation or harassment and must meet or exceed relevant requirements of local law.
Health And Safety
We are committed to providing our people with a safe and secure working environment that safeguards their health, and promotes physical and mental wellbeing, regardless of where in the world they work. Our suppliers are expected to support our commitments by ensuring they comply with all applicable health and safety laws and regulations in the jurisdictions in which they operate, have the appropriate arrangements in place for managing health and safety, and be able to provide their goods and services safely, without risks to health.
As a minimum, we expect our suppliers and business partners to:
- comply with our health and safety requirements while on our premises; including, but not limited to agreed method statements and permit to work arrangements including signatures, time and dates;
- report all incidents and near misses related to the contract;
- provide their health and safety policy statement, management arrangements, and insurances on request.
We are fully committed to minimising the environmental footprint of our business operations while contributing globally to the evolving societal goals for sustainable development. We require our contractors, suppliers and service providers to have environmental sustainability commitments and operating standards comparable to our own or at the very least to be working towards achieving them.
We are signed up to Science Based Targets to reduce our carbon emissions substantially by 2030 and to move to net-zero by 2050.
We prefer to work with suppliers that have the greatest potential to influence our sustainability performance and to support us in delivering our environmental commitments, including but not limited to:
- minimising the use of resources such as electricity, gas, water, paper;
- reducing the carbon footprint associated with our services in line with what science says is necessary to achieve a 1.5°C degree world;
- diverting all waste generated by our offices away from landfill.
Ethical Business Practice
Integrity is vital for a sustainable relationship with suppliers and we will not tolerate corruption or bribery in any form. We expect all suppliers to uphold the highest standards in ethical business practice and comply with requirements of all applicable anti-corruption laws. Our zero-tolerance approach requires all suppliers and business partners to have in place policies, systems and/or procedures to ensure zero tolerance towards, but not limited to, human rights abuses, money laundering, fraud, bribery, tax evasion, conflicts of interest, corruption and other improper payments, benefits gifts or other inducements.
Confidentiality And Information Security
Our suppliers and business partners must have robust cybersecurity processes and controls in place to protect data and confidential information. Suppliers must adopt and maintain processes to provide reasonable protections for personal, proprietary and confidential information, including information that they access, receive or process on behalf of Odgers Berndtson. In addition, suppliers must comply with all applicable privacy/data protection and information security laws and regulations.
Privacy And Data Protection
We expect our suppliers to protect personal information they process on our behalf. Suppliers must adopt and maintain processes to ensure compliance with applicable data protection and privacy laws and provide reasonable protections for personal information, including information that they access, receive or process on our behalf. Suppliers should recognise that unauthorised use and/or disclosure of such information may have severe, legal, reputational and financial consequences
Our suppliers, clients and business partners must comply with our security requirements when working with us and commit to the protection of our people, property, assets and reputation. Visitors on our premises must be escorted as far as reasonably practicable; not enter working floors without authorisation; not take any photography or video without prior written approval; comply with all applicable legislation and relevant regulatory requirements; take responsibility for their personal items; comply with any ad hoc requirements that may be implemented depending on their scope of work.
Our suppliers and business partners must have adequate and relevant insurance including, but not limited to, public and product liability and professional indemnity insurance which is current for the duration of the contract. They must comply with any request to provide proof of insurance or other related information and keep the firm abreast of any material changes.
Our suppliers and business partners must seek our written consent before any sub-contracting.
Inclusion is in our DNA.
We expect our suppliers to share the same commitment to being diverse and inclusive, both in their operations and supply chains.
In return, our suppliers will be treated fairly and equally during the tendering and purchasing process, with decisions made based on clear selection criteria.
Suppliers should take all steps required to be inclusive in their operations, which include but are not limited to:
- treating workers with dignity and respect at all times;
- ensuring that all laws and any applicable discrimination legislation are complied with regarding the fair treatment of people;
- providing a fair and transparent recruitment and hiring processes;
- providing a workplace free from discrimination, bullying, harassment or inappropriate behaviour;
- ensuring that no person experiences disadvantage based on (but not limited to) the following:
- age, disability, ethnicity, faith, gender, gender identity, marital status, parental status or pregnancy, sexual orientation, social origin or any other underrepresented group;
- having a stated commitment to being diverse and inclusive and being able to demonstrate active compliance if requested.
These Standards set out our expectations for current and future suppliers. We expect all new and existing suppliers to meet our minimum expectations as noted.
We encourage suppliers to institute effective management systems that use the best available techniques and practices to adhere to these Standards and continuously improve their performance. This should include a process for the identification and proactive mitigation of risks associated with compliance to these Standards, as well as a process for ongoing monitoring and review of risk controls, and prompt and accurate reporting of all incidents.
Failure by a supplier to comply with these Standards may lead to a review of our relationship or possibly termination of our relationship. We reserve the right to audit our suppliers in accordance with these Standards.
We are committed to continuously review and updating these Standards. Therefore, this document is subject to modification from time to time.
The contents of this Standards are additional to and do not in any way affect or prejudice any of Odgers Berndtson’s rights and remedies under the relevant contracts with each supplier, if any. In the event of any non-compliance with the requirements of this Standards or breach of contract, we reserve the right and retain the sole discretion to exercise any rights under this Standards, any relevant contract and/or local laws and regulations.
The failure or omission to comply with the requirements of these Standards may constitute a breach of contract. In the event of any conflict or ambiguity between any provision of these Standards and the provisions of any relevant contract with any supplier, the provisions of that contract will prevail.
We use analytics tools and cookies on this website to help deliver our online services, identify any service issues, improve our services, provide content tailored to users' personal preferences, and to monitor site traffic and usage.
These tools may be provided by third-party service providers and may include the collection and tracking of certain data and information regarding the characteristics and activities of visitors to our website. We may disclose data, including personal data, to certain third-party services providers in order to obtain such services.
One of these providers is Google Analytics. More information about the ways in which they collect and process your personal data can be found here: www.google.com/policies/privacy/partners
You can opt-out of Google Analytics here: tools.google.com/dlpage/gaoptout
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
Cookies are small computer files which are downloaded onto your device when you browse the web. They collect information about the way in which you navigate and use this website and the wider web. This information may allow us to identify you or your approximate location. Cookies also help us provide you with a more personal experience, like a local version of the website in a local language. Information from cookies also allows us to make improvements to our services.
We only collect "session" cookies, which are not usually stored after your browsing session has ended. These are used to establish your approximate location and to serve up the website in an appropriate language.
You may delete and block all cookies, or just certain types of cookie, via your browser setting. However, if you choose to block or delete cookies, this may affect the functionality of the website.
The procedure for deleting or disabling cookies on your device depends on the browser you are using. Please follow the guidelines via the following links depending on the browser you are using:
Third party websites
This Policy only applies to this website. If you land on our site from other websites, or move to other ones from our website, you should read their separate privacy policies.
Odgers Berndtson Denmarkis committed to achieving and maintaining the highest possible standards with regard to behaviour at work, services to the public and in all of our practices. Our people are expected to conduct themselves with integrity, impartiality and honesty.
Odgers Berndtson Denmarksees effective whistle blowing as a key component in our strategy to challenge inappropriate behaviour at all levels in the organisation. It is both an instrument in support of good governance and a manifestation of a more healthy and ethical organisational culture.
If you wish to make a whistleblowing report you should contact the Odgers Berndtson Danmark at firstname.lastname@example.org.
If you have a complaint about how we have handled your personal data, contact us using the details below, and we will investigate your complaint. Please use the same contact details to instruct us to cease processing your personal data. You may also file your complaints with the Danish Data Protection Agency (in Danish “Datatilsynet”), Borgergade 28, 5, 1300 København K, phone no. 33 19 32 00, e-mail email@example.com.
Odgers Berndtson P/S
CVR no. 42520780
CVR no. 31596181
28. August 2023
Review and process update