Effective Date: 18 November 2020
Version No: 4.1
CHANGES TO THIS NOTICE: To address the European Union Court of Justice invalidating the EU-US Privacy Shield in July 2020 and the United Kingdom no longer forming part of the European Union from 1 January 2021.
1.1 Our Privacy Notice
SHL takes its obligations to protect privacy and personal information very seriously. Please read this Privacy Notice (the Notice) carefully as it sets out important information relating to how we handle your personal information.
1.2 SHL companies issuing the Notice
In this Notice, references to “we“, “us“, or “SHL” are references to SHL Global Management Limited and all its group companies. This Notice sets out how we, as data controller, will collect and use personal information, and the choices and rights available to you in connection with our use of your personal information.
1.3 To whose personal information does this Notice apply?
This Notice describes our practices when using the personal information of:
other persons who (1) may visit our websites such as shl.com, or other SHL websites that link to this Privacy Notice including users that sign up for a TalentCentral account (website users) or (2) who may visit our SHL pages on social media sites. TalentCentral means any of the following domains: talentcentral.us.shl.com, talentcentral.eu.shl.com, talentcentral.au.shl.com, or talentcentral.cn.shl.com
This Notice will apply whether you have provided the information directly to us or we have obtained it from a different source, such as a third party.
Our websites contain business-related content and are specifically aimed at and designed for use by adults. We do not knowingly solicit or collect personal information from or about individuals under the age of 18 years.
This Privacy Statement does not apply to data collected via SHL’s Talent Assessment systems which are governed by the terms of the specific Data Protection Notice (“DPN”) available at the beginning of each assessment.
2.1 Sources of business contact information
We collect personal information from our business contacts directly or from the following sources:
2.2 What personal information we collect about business contacts
The categories of information we collect about business contacts includes:
Log-in and similar account credentials and information about use of these services;
2.3 How we use the personal information we collect about business contacts
We use this information for certain activities, including:
2.4 Why we use the personal information of business contacts
We use this information because:
In limited circumstances, such as in the case of marketing, a business contact’s consent is required under applicable law. Where we rely upon a business contact’s consent, they will have the right to withdraw their consent by contacting SHL’s Global Data Protection Officer (DPO).
If a business contact requires further information regarding our legitimate interests as applied to their personal information, they may contact the DPO on the contact details below.
In certain circumstances, where a business contact does not provide personal information which is required, we will not be able to perform our obligations under the contract with them or may not be able to provide them with products and services. We will make it clear if and when this situation arises and what the consequences of not providing the information will be for the business contact.
3 WEBSITE USERS AND WEB-RELATED PRIVACY ISSUES
3.1 What personal information we collect about website users and visitors to SHL’s social media pages
The categories of information we collect about users of our website and SHL webpages on social media sites such as Facebook, YouTube, LinkedIn, WeChat and Twitter include:
3.2 How we use the personal information of website users and visitors to SHL social media pages:
We use personal information of users of our website and SHL webpages on social media sites such as Facebook, YouTube, LinkedIn and Twitter for certain activities, including:
3.3 Why we use the personal information of website users and visitors to SHL social media pages:
We use personal information of users of our website and SHL webpages on social media sites such as Facebook, YouTube, LinkedIn and Twitter because:
If a website user or individual accessing our web pages on social media sites requires further information regarding our legitimate interests as applied to their personal information, they may contact the DPO.
In certain circumstances, where a website user does not provide personal information which is required (for example, in relation to our online services), we will not be able to perform our obligations under the contract with them or may not be able to provide them with products and services. We will make it clear if and when this situation arises and what the consequences of not providing the information will be for the website/social media site user.
4.1 What personal information we collect about TalentCentral users
The categories of information we collect about users of talentcentral.com include:
4.2 How we use the personal information of talentcentral.com users
We use personal information of users of TalentCentral for certain activities, including:
4.3 Why we use the personal information of TalentCentral users
We use personal information of users of TalentCentral users because:
In certain circumstances, where a website user does not provide personal information which is required (for example, in relation to registering for a TalentCentral account), we will not be able to to provide them with access to TalentCentral. We will make it clear if and when this situation arises and what the consequences of not providing the information will be for the TalentCentral users
4.4 Information we collect from third party sites
We may also get information about you from other sources. For example, if you create or log into your talentcentral.com account through another third-party website such as Facebook or Google. We will receive information from your selected third- party service provider (such as name and email address) via the authorization procedures used by such third-party service provider. The information we receive depends on which services you authorize and any options that are available.
By accessing TalentCentral through your Facebook, Google or LinkedIn account, you understand that Facebook or Google will share certain data detailed in the above paragraph with SHL for the purposes of authentication to permit you to access TalentCentral in a secure manner. You may stop this at any point from your Facebook or Google account. This information will be considered SHL account information for purposes of your use of the TalentCentral.
You have the ability to disable the connection between your Facebook or Google account and your TalentCentral account at any time by accessing your privacy settings on your Facebook or Google account. Facebook or Google may also ask for your permission to share certain other details with SHL, including but not limited to your name, profile picture, public profile information, and email address. Once you give this permission, the requested information will be shared with SHL, SHL may use this information to provide Services to you. The shared information will remain associated with your TalentCentral profile until you modify or delete it.
PLEASE NOTE THAT YOUR RELATIONSHIP WITH FACEBOOK OR GOOGLE, OR ANY OTHER THIRD-PARTY WEBSITE IS GOVERNED SOLELY BY YOUR AGREEMENT WITH SUCH THIRD-PARTY WEBSITE.
We may disclose personal information of business contacts and website/social media site users to third parties as follows:
We may transfer personal information we collect about our business contacts and website/ social media users outside the European Economic Area (EEA), the United Kingdom (UK) and/or Switzerland including to the USA and/or countries that do not have equivalent data protection laws to those applicable to the EU, UK and Switzerland, and to any other country in which we have offices. Privacy laws in these countries may not provide protections equivalent to those of your country of residence. It may also be processed by staff operating outside the EEA, UK or Switzerland who work for us or for one of our affiliated companies.
However, to ensure your personal information is properly protected in line with EU, UK and Swiss data protection laws, the transfer of this information is governed by a contract including Standard Contractual Clauses approved by the European Commission in accordance with Article 46(2)(c) of the European General Data Protection Regulation (GDPR).
We will only transfer data to jurisdictions outside the scope of the GDPR where the appropriate safeguards set out in the GDPR are in place. SHL will use all reasonable efforts to ensure that personal information is protected and any such transfers comply with applicable law.
PRIVACY SHIELD: SHL continues to maintain its Privacy Shield certification but SHL does not rely on EU-U.S. Privacy Shield to transfer data that originated in the EEA or the UK to the US. SHL’s Privacy Shield Statement can be found here or at www.shl.com/privacyshield
For complaints from EU, UK or Swiss data subjects that cannot be resolved with SHL directly, SHL has chosen to cooperate with EU data protection authorities (DPAs) and Swiss Federal Data Protection and Information Commissioner (Commissioner) and will comply with information and advice the DPAs and/or Commissioner may provide in relation to such unresolved complaints. The relevant DPA may be contacted here. The Commissioner may be contacted here.
If you require more information on the safeguards identified above, you can contact the DPO on the contact details below.
We will keep your information for as long as it is reasonably necessary to provide our services to you, to comply with legal, tax, accounting or reporting requirements and to protect and defend against legal claims. The time period will depend on factors such as whether you have registered an account with us or agreed to receive marketing from us.
If you wish to obtain further information about the retention periods as applied to your personal information, you can contact the DPO on the contact details below.
We have listed the rights you have over your personal data 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. You can exercise these rights by contacting the DPO on the contact details below.
8.1 The Rights
You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident where we are based or where an alleged infringement of data protection law has taken place.
8.2 Direct Marketing
You can opt-out of receiving directing marketing from us at any time. You can do this by contacting us on the contact details below or by clicking the “unsubscribe” button within our correspondence with you.
9.1 Security
We have put in place technical and organisational security measures to prevent the loss or unauthorised access of your personal information. We train our employees in the proper handling of personal information. However, whilst we have used our best efforts to ensure the security of your data, please be aware that we cannot guarantee the security of information transmitted over the Internet. If you have reasons to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us as set out below.
9.2 Links
Our Website may contain links to other “non-SHL” websites. We do not control and assume no
responsibility for the content, security or the privacy policies and practices on those websites. SHL encourages all users to read the privacy policies of those sites to determine how they protect and use personal information.
9.3 Changes to this 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 link to it for a reasonable length of time following the change on the Website.
If you would like to access previous versions of this Notice please click on the link to archived policies at the top of this page or contact us on the contact details below.
9.4 How to Contact Us
If you have any questions regarding our Notice you can contact us at: dpo@shl.com or by regular mail addressed to:
For users in the European Union (EU), European Economic Area (EEA), and Switzerland:
SHL Nederland BV
Attn: Global Data Protection Officer,
Secoya Building 5th Floor
Papendorpseweg
99 3528 BJ Utrecht
The Netherlands
For all other users:
SHL Group Ltd
Attn: Global Data Protection Officer
The Pavilion
1 Atwell Place, Thames Ditton
England KT7 0NE
UK.