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Privacy Policy |
Introduction to the Administrator Data Protection Notice Please read this Data Protection Notice (“Notice”) to continue. It sets out how and why your Employer and SHL collect your personal information. For any defined terms which are not defined on this page, please see the definitions included within the Notice. Please read the entire Notice carefully. If you have questions about this Notice, please email dataquestions@shl.com
Administrator Data Protection Notice This Notice was last updated on 22 March 2019. CHANGES TO THIS NOTICE: This Notice has been updated to address the possibility of the United Kingdom leaving the European Union and the migration of our data storage facilities during 2019.
1 Who we are This Notice describes how: (1) your Employer (“Employer”); and (2) SHL US LLC of 111 Washington Avenue S, Suite 600, Minneapolis MN 55401, USA (together, SHL or we or us) respectively use your information collected as an administrator of the online Assessment. SHL will process and collect information about you as the administrator of the SHL assessment platform (“Platform”) in accordance with this Notice. Some information is ("Personal Information"), personal information about you or from which we can identify you. This Notice also covers us, and our affiliated group of companies. Each group company is listed here. This Notice sets out the way the Employer and SHL use your information: what is collected, how it is collected, how it is used, why it is used, who it is shared with and the rights to which you will be entitled. Section 2 (Employer as the Data Controller) provides further information on processing of your personal information by the Employer as the data controller. Section 3 (Data Sharing and Your Rights) provides additional information on who SHL and the Employer share your data with and an overview of your rights under data protection law.
2 Employer as the Data Controller SHL collects your Personal Information on behalf of your Employer so that you can operate the Platform where your Employer conducts assessments with candidates and participants. The Employer will be the data controller in respect of your Personal Information and the Employer will decide what data is collected, the purposes for which it is collected and who it is shared with. You will be able to exercise your rights directly against the Employer in respect of this Personal Information (see section 4 (The Employer and SHL as the Data Controller) for more information)). The data collected We collect and process the categories of data on behalf of the Employer as set out below. Depending on the Platform, not all the categories of data listed below may be collected about you. What we collect Information that you give us and the Employer when you become an Administrator, ("Admin Credentials") including:
What we do with the data We use your Admin Credentials to:
Why this data is collected and how long it is retained by us We hold and process your Admin Credentials, in accordance with the Employer''s instructions. The Employer will instruct us to process your Personal Information because they have one or more of the following legitimate interests:
We will keep your Personal Information on behalf of the Employer in accordance with the Employer''s instructions. The period of time that we are instructed to hold your Personal Information, varies from Employer to Employer, but generally will be for the time that we are instructed to retain the related assessments. We will not delete your Personal Information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved. You should contact the Employer directly if you require more information on this section. Data Sharing We will only share your Personal Information processed on behalf of the Employer with the Employer and on the Employer''s instructions. The Employer may share your Personal Information with other third parties including its group companies and those parties listed at section 4. You should contact the Employer for more information to identify with whom they share your Personal Information. Where your Personal Information will be held We store your Personal Information in data centres located in the United States and backed up in the United States. SHL affiliates also transfer your Personal Information within the EEA (Europe Economic Area). Additionally, your Personal Information is transferred to the United States, India, South Africa and United Kingdom (“SHL Non EEA Processing Locations”) where a limited number of personnel in our SHL Non EEA Processing Locations, as well as our trusted third party vendors and service providers, have access to Personal Information in order to provide services. As the SHL Non EEA Processing Locations are in countries which do not have equivalent data protection laws to those applicable in the EEA we have an Intragroup Agreement in place, signed by all SHL affiliates, which contains the European Union (EU) Standard Contractual Clauses (SCCs) which have been approved by the EU data protection authorities for the transfer of data outside the EEA. Our third party vendors and service providers are also required to sign up to SCCs in accordance with Article 46 of the General Data Protection Regulation. All SHL affiliates have the same technical, physical, and administrative security controls and are required to comply with our data protection policies and procedures, applicable laws, governing the collection and use of personal information. We are happy to provide you with copies of the regulator-approved SCCs, which you can request from the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice. When do we share Personal Information We have set out the circumstances in which we will share your data with third parties below:
3 Data Sharing and Your Rights Data Sharing The Employer and SHL as data controller will share your data with the following third parties in the below circumstances:
Data Subject Rights We've listed the rights you have over your Personal Information and how you can use them below. These rights are subject to exemptions in applicable law and will only apply to certain types of information or processing. As described above, the Employer will be data controller so you should contact them directly if you want to exercise a right over data for which they are data controller.
You also have a right to make a complaint to a Supervisory Authority. Where we are the data controller you can contact the UK Information Commissioner's Office; or the local data protection regulator in your jurisdiction. Where the Employer is the data controller, you can contact the regulator in the location where the Employer is based. Questions or Complaints Questions about the results of your assessment or the Employer’s use of your Personal Information should be sent directly to the Employer at whose request you are taking the assessment. If you have any questions about this Notice please contact the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice. Changes to the Notice This Notice will be changed from time to time. If we change anything important about this Notice (the information we collect, how we use it or why) we will provide a prominent notice to bring your attention to such importance changes for a reasonable length of time following the change. If you would like to access previous versions of this Notice, please contact the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice.
Other policies Security We are committed to keeping your personal information safe. We have implemented physical, technical and administrative measures to help prevent unauthorized access or use of your information. For more information about the security measures we have please see our: Security Policy. Sanctions SHL products and services are subject to US sanctions law. As a result, prohibited individuals, or those located in certain countries (Cuba, Iran, North Korea, Sudan and Syria), are not authorized to take assessments on our systems. Please contact us at dataquestions@shl.com with any questions. SHL Data Protection Officer Contact Details : Email: dpo@shl.com Postal Address: Data Protection Officer, SHL Group Ltd, The Pavilion, 1 Atwell Place, Thames Ditton, Surrey, KT7 0NE, England.
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