November 2018

CANDIDATE PRIVACY INFORMATION STATEMENT

This privacy information statement pertains to the collection and use of information about you by EMEA EXECUTIVES Limited. (and/or its applicable affiliated companies such as, for example, EMEA CYBER EXECUTIVES, CYBER SENTINELS, EMEA SALES EXECUTIVES). As you’d expect, to properly perform our services and/or to maintain our relationship with you, we collect and use information about you.

EMEA EXECUTIVES is committed to protecting and respecting your privacy. This Candidate Privacy Information Statement describes your privacy rights in relation to the information about you that we process, as well as the steps we take to protect your privacy. We know it’s long, but please read this Statement carefully. There is an index below so you can go straight to the bits you want if you prefer.

Index

Some terms to be clear about.

What personal information does the company collect and use?

Why do we use personal information about you?

What does the law say about this?

Do you have to give us the personal information we ask for?

Do we process information about you without any human intervention at all?

How long do you keep my personal information for?

Do we transfer your data to third parties?

Do we transfer your data outside the European Union?

What are your rights?

What about data security when using EMEA EXECUTIVES Systems?

How do we handle changes to this Statement?

Some terms to be clear about

First, we need to be clear about how we use some words in this Statement.

It may seem obvious, but in this Statement you will be referred to as ‘the Candidate’ or ‘You’.

When we talk about ‘us’ or the ‘Company’ or ‘EMEA EXECUTIVES’, we mean EMEA EXECUTIVES Solutions, Inc. (or its applicable affiliate company with which you are working such as, for example, EMEA EXECUTIVES Limited). We have a registered address at Cotford House, Fair Oak, Eastleigh, Hampshire, SO50 7HP. The Company, and all of our affiliated companies, are part of the EMEA EXECUTIVES, a company providing Digital Transformation Talent Acquisition Solutions. Through its various companies and business lines the EMEA EXECUTIVES provides several HR (Human Resources) activities like staffing, secondment, payroll services, recruitment & selection, testing solutions, career transition, talent development, training & education, outplacement and international mobility (‘our Activities’).

To carry out our Activities, the Company may use several IT systems. In some cases, the Company provides a Self Service Portal (‘Portal’) for its candidates/personnel. Such Portal may allow you to search and apply for jobs the Company and its sister companies advertise which match your interests, skills and/or experience, in the locations where you have expressed an interest in working.

Finally, this is a Statement about information about people – like you and your family. It includes facts about you and also opinions about you and that you hold (“I’m a Harley Davidson Motor Cycle Rider”, for example). This Statement is not about information about the Company (although sometimes the two overlap). Information about you as described above is sometimes called ‘Personal information’, ‘Personally Identifiable Information’ or ‘PII’. We use the term ‘Personal Information’ in this Statement.

What Personal Information does the Company collect and use?

Personal Information that the Company usually collects includes, but is not limited to:

your name, date and place of birth, contact details and qualifications (education, training courses and internships), documents evidencing your identity and right to work and any other information you listed on your resume or CV;

 if you log on to the Portal using your LinkedIn or any other social media account: your profile data;

 if you contact us, in some cases we will keep a record of that correspondence;

feedback about you from our staff and third parties; where you give feedback on others, we usually keep that too and that is also personal information about you (it’s your opinion after all); we may also collect information on your visits to our website/Portal including (but not limited to) your IP address, browser, timestamp, location, country traffic data, location data, weblogs and other communication data and the resources that you access. This information will make your visit to our website/Portal easier in the future. We might, for example, suggest jobs to you which are being handled by branches local to where you were when you contacted us; we may also collect information for marketing purposes and analysis, including information on how your respond to email, SMS, phone and other marketing campaigns; photos and videos of your attendance at training or similar sessions (you will be given a chance at the session to ask not to be videoed or photographed to the extent applicable law requires such); details of any disabilities and any accommodations we may need to make for you in the workplace; and in some cases we will also collect sensitive Personal Information where we are permitted to do so by law (so in some countries we may ask you about your background for equal opportunities monitoring).

Why do we use personal information about you?

The Company collects and processes Personal Information:

1. To provide you with the services you expect us to, like finding you suitable jobs/assignments to apply for, helping you with training, or facilitating the process of applying for jobs/assignments. This may include sending your CV to prospective employers for their consideration and keeping you informed of future work opportunities by email, telephone, mail and/or other communication methods;

2. with your consent we may also use your contact data for direct marketing for example via e-mail, messaging or telephone;

3. to further develop, test and improve our website/Portal, or other existing or new systems/processes to better serve you; this mainly takes place in the context of new IT systems and processes, so that information about you may be used in the testing of those new IT systems and processes where dummy data cannot fully replicate the operation of that new IT system;

4. to perform studies and statistical and analytical research, for example to compare the effectiveness of our placement of candidates between different business sectors and geographies and seek to identify factors that might influence any differences we identify;

5. to transfer data to third parties (see below);

6. where necessary, to comply with any legal obligation; and

7. we may also process your information to: a. promote the security and protection of people, premises, systems and assets;

b. monitor compliance with internal policies and procedures;

c. administer communications and other systems used by the EMEA EXECUTIVES (including internal contact databases);

d. investigate or respond to incidents and complaints;

e. in the case of photos or videos of training sessions, to report internally that the training sessions have taken place and their content (for example in internal updates) and also to market similar sessions internally and externally to third parties;

f. comply with obligations and rights and cooperate with investigations carried out by the police, government or regulators; and

g. participate in any potential or actual purchase or sale, or joint venture, of all or part of a business or company, that any member of the EMEA EXECUTIVES wishes to participate in.

What does the law say about this?

In many jurisdictions such as, for example, the European Union, we are required to have a ground set out in the law to process the Personal Information we hold about you.

In the EU when you are working with or through EMEA EXECUTIVES our processing of Personal Information is based on processing grounds such as the performance of a contract to which the data subject is a party (purposes 1 and 6-7), processing necessary to comply with legal or regulatory obligations (purpose 6-7) and/or processing necessary in the legitimate interests of EMEA EXECUTIVES in exercising its and its staff fundamental rights to run a business in a way which does not unduly affect your interests or fundamental rights and freedoms (purposes 1-5 and 7). When processing is necessary for the legitimate interests of EMEA EXECUTIVES, we ensure that processing is conducted in such a manner that our legitimate interests outweigh any individual’s interest. We shall only process your personal information other than on these grounds with your consent (a further processing ground).

 

Do you have to give us the Personal Information we ask for?

You are not obliged to provide your Personal Information to us, but it is more or less impossible for us to work with you and provide our services if you do not.

Do we process Personal Information about you without any human intervention at all?

Yes we do at times. The Company may use automated systems/processes and automated decision-making (like profiling) to provide you, and our clients, with the services you request from us. For example, when our clients are looking for candidates for jobs, we may conduct a search of our lists of candidates using automated criteria which takes into account your availability, skillset, pay rate and in some circumstances previous feedback we have received from clients to compile a shortlist which ranks which candidates are most likely to fulfil the client’s requirement. This means that sometimes your position in the rank may be higher than others, depending on how these factors match the client’s needs.

How long do you keep my personal information for?

The length of time that the Company retains your Personal Information depends on a number of factors including but not limited to the type of information, HR and legal obligations, the legitimate need by the Company for such Personal Information in order to provide its services, and other legitimate circumstances. If you are successful in finding work through us, the Company will most likely need to keep your personal information for a longer period in order to comply with its on-going legal and contractual obligations. In any case, we are committed to retaining your Personal Information only as long as reasonably necessary and in no event longer than applicable law allows for.

Do we transfer your data to third parties?

As mentioned above, we usually disclose your data to third parties. This is done to complete the purposes set out above. We may do this in the following circumstances:

• To our vendors. We may, for example, engage a vendor to carry out administrative and operational work in support of our relationship with you. The vendor(s) will be subject to contractual and other legal obligations to preserve the confidentiality of your data and to respect your privacy, and will only have access to the data they need to perform their functions; the relevant vendors are typically IT vendors (who host or support our IT systems, including information about you), premises management companies (who look after physical security at our buildings, and therefore may need to know about you to allow access to our buildings) and back office finance and accounting management providers (who might need to handle details of candidates in order to process accounts payable and receivable). We may also engage vendors who provide IT technology services and solutions, which might include for example video interview and skills assessment tools.

• To members of the EMEA EXECUTIVES of companies, many of which exist in other countries. These may be located in- or outside the European Union; different members of the group fulfil different functions and as result your information may be shared with them for different reasons:

o information is shared with members of the EMEA EXECUTIVES that provide IT functions for EMEA EXECUTIVES and other EMEA EXECUTIVES companies world-wide; these functions are located in many different countries across the world, both inside and outside the European Union.

o information is also shared with EMEA EXECUTIVES affiliates world-wide where you have   expressed an interest in opportunities in that market, or members of the EMEA EXECUTIVES identify that you may have particular skills required or helpful in that market. A list of the countries in which we operate is available in the ‘choose your country’ function of our website at www.EMEAEXECUTIVES.co.uk

• To our clients/prospective employers: we may share your data with clients of ours who are offering jobs/assignments you may be interested in, or who are interested in your profile. They owe contractual and other confidentiality obligations in relation to your data to us, and to you;

• We will share your data with government, police, regulators or law enforcement agencies if, at our sole discretion, we consider that we are legally obliged or authorised to do so or it would be prudent to do so; and

• As part of due diligence relating to (or implementation of) a merger, acquisition or other business transaction we may need to disclose your data to the prospective seller or buyer and their advisers.

Do we transfer your data outside the European Union?

Your data can be transferred and processed in one or more other countries, in- or outside the European Union. A full list of the countries in which we operate is available in the ‘choose your country’ function of our website at www.emeaexecutives.co.uk

We shall only transfer your data outside the EU to countries which the European Commission believes offers an adequate level of protection to you (a list of those countries is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm or where the EMEA EXECUTIVES has put in place appropriate safeguards to seek to preserve the privacy of your information (for which we usually use one of the forms of data transfer contracts approved by the European Commission, copies of which are available here: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.

What are your rights?

 Right to access and obtain a copy of your personal information

You are entitled to request confirmation whether we process any of your Personal Information. Where this is the case, you may have access to some of your Personal Information (via the Portal) and to certain information about how it is processed. In some cases you can ask us to provide you with an electronic copy of your information.

 Right to correct your personal information

If you can demonstrate that Personal Information we hold about you is not correct, you can request that this information is updated or otherwise corrected. We would encourage you to access the self-service Portal where possible, to the extent such is available, and update your Personal Information directly.

 Right to be forgotten/have data deleted

In certain circumstances you have the right to request that we restrict the processing of your Personal Information and/or that your Personal Information be deleted. You may make such a request at any time and EMEA EXECUTIVES will evaluate if your request should be granted, however this right is subject to any legal rights or obligations we may have to retain data. For situations where in accordance with the law, we determine that your request to have your Personal Information deleted must be granted, EMEA EXECUTIVES will do so without undue delay. Please bear in mind, once your data is deleted – that the Company might not be of service to you anymore once this data about you has been deleted. If you want to re-register with the Company again, you will need to re-enter your data.

As far as the Company’s processing of your data being based on the Company’s legitimate interest (and no other processing ground) or relates to direct marketing, you are entitled to object to the Company processing your data by reference to your particular situation.

If you want to exercise any of your rights, please log into the self-service Portal, to the extent such is available, or email us at Privacy@EMEAEXECUTIVES.co.uk

When you email us to exercise your rights, the Company may ask you to identify yourself before actioning your request.

Finally, you have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your data has arisen.

What about data security when using EMEA EXECUTIVES Systems?

If provided a login for a Portal or other system, you are responsible for keeping such safe, in particular the password that we have given you or that you have chosen. These login credentials are for your own use. You are not permitted to share your credentials or other account details with any other person(s).

How can you contact us?

If you have any questions or concerns regarding our Statement, would like further information about how we protect your information (for example when we transfer it outside Europe) and/or when you want to contact the Company’s Group Data Protection Officer (DPO) or your Local Privacy Lead, please email us at Privacy@EMEAEXECUTIVES.co.uk

How do we handle changes to this Statement? January 2018

The terms of this Statement may change from time to time. We shall publish any material changes to this Statement through appropriate notices either on this website or contacting you using other communication channels.

The EMEA EXECUTIVES team

V1 November 2020

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