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.com, www.berwickpartners.co.uk, www.odgersinterim.com, www.odgersinterim.ca, www.berwicktalentsolutions.com, www.odgersconnect.com
Who we are
We are AII Ltd. We represent the global businesses that trade as Odgers Berndtson. 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 ("we", "us") 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 September 2019. Please review this policy periodically for any changes.
Who this policy applies to
We provide executive search, assessment and leadership services, interim managers and independent consultants (“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;
a referee is a person who provides a personal or work reference in respect of a candidate and;
a source is a person who provides us with information or intelligence about a candidate.
Section 1 - Gathering Information
Section 2 - How we use your personal data
Section 3 - The type of personal data we collect and process
Section 7 - Your right to object and to have your data erased
Section 8 - Newsletters and other communications
Section 9 - Satisfaction surveys
Section 10 - Providing information to others
Section 12 - Keeping information secure
Section 13 - Information about others
Section 14 - Keeping your records
Section 16 - About our websites
Section 17 - Updating your account and preferences
Section 20 - Third party websites
Section 21 - Complaints procedure
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 your CV or resume to our candidate portal or when you send this to us via email or post. We also collect information from you when you speak with an Odgers Berndtson 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 service 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.
Source and Referee
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.
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, references and referees, amongst other things.
Based on your explicit consent, we will also process any relevant psychometric assessments, psychological tests, or results from such assessments or tests.
From time to time, we may ask you to provide information relating to protected characteristics, such as your race or marital status. We do this for equal opportunity monitoring purposes and from time to time online, but only if that’s admissible under local law. This information is always anonymised and aggregated and will not be revealed to third parties without your specific consent.
We might also collect personal data from third-party databases and other public sources.
As well as basic contact information we will also collect information about your role and other information provided to us by your organisation.
Source and Referee
As well as basic contact information we will also collect information regarding your credentials as a source, details of your relationship/knowledge of a candidate and your opinions of that individual. We may obtain this information directly from you or publicly available information.
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 to process personal data in respect of certain specific and limited purposes. We will always do this before processing any sensitive personal data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sex life and sexual orientation, genetic and/or biometric data. We encourage you not to provide us with sensitive personal data unless it is specifically requested, and we have your consent.
In certain countries, we will not collect personal data from you unless you have specifically agreed to this. Your agreement might come via an electronic tick-box on our website or other electronic channels, or via other similar measures required by local privacy and data protection laws.
To consult local privacy policies where they apply, please select the relevant country below:
We may also provide services to our clients in certain countries 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 obtain your specific consent.
In some locations, 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.
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 any of our services.
Remember, you may withdraw any consent you have previously given, at any time. Also, you have the right to ask us to stop processing any personal data and to have it erased.
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.
When you have indicated you would like to receive newsletter(s) from us, we may send email alerts and bulletins about our services and any roles that might interest you.
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.
From time to time, we may contact you with updates on our services, terms of business or simply to ensure that the data we hold is current, relevant and up to date.
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.
Providing information to others
To help us run this website, and to provide executive search services or assessment services in certain countries, 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 to 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 certain countries.
- 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 you are concerned about these arrangements to disclose or share personal data with third parties, you should contact us and ask us not to process your personal data.
Keeping information secure
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 some jurisdictions, 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, in countries 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
The primary purpose of our websites is to provide you with information regarding the services provided by the Odgers Berndtson group of companies and consultants. In certain countries, you may use a site to view and apply for jobs.
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 certain countries. 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.
Finally, we might also use your data, to help our clients understand who is making use of our website and how their job vacancies are being viewed.
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.
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. (IP address collection happens during this process.)
You may delete and block all cookies, or just certain types of cookies, via your browser settings. However, if you choose to block or delete cookies, this may affect the functionality of the website.
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.
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.
Herbert Park Lane
Dublin, D04 H6Y0
You can also contact our Data Protection Officer, David Peters at email@example.com