Lee Hecht Harrison Knightsbridge Corp. Privacy Notice

Statement of Privacy

Lee Hecht Harrison Knightsbridge Corp. respects your privacy and is committed to protecting your privacy in compliance with applicable data protection laws. This privacy notice describes how Lee Hecht Harrison Knightsbridge Corp. ("LHH Knightsbridge” or "we", "us", or "our" or “the Company”) processes and protects your Personal Data in connection with our recruitment and interim management services. 

We have our registered office at Suite 600, Upper Water Street, Halifax, Nova Scotia B3J 2X2.   We are part of the Lee Hecht Harrison group of companies, which are all affiliated with the Adecco Group, the largest HR services provider in the world.

+Some terms to be clear about (Definitions)

In this Notice you may be referred to as a ‘Candidate,’ the ‘Interim Manager’ or ‘You’. 

To carry out our services LHH Knightsbridge uses several IT systems. In some cases, LHH Knightsbridge may provide a Portal (‘Portal’) for your use in searching for opportunities and providing your resume/CV to us. The Portal allows you to search and apply for jobs LHH Knightsbridge advertises which match your interests, skills and/or experience, in the locations where you have expressed an interest in working. and to submit your resume for our consideration in connection with available positions with our clients, including interim manager assignments.

What do we mean by personal information:

- Personal information means, any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

- “Special Categories” means personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”

+What personal information does LHH Knightsbridge collect and use?  

Personal information that LHH Knightsbridge usually collects includes, but is not limited to:

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

• if you set up a profile and log on to our Portal, or you log in 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 (such as persons who provide a reference on your behalf);

• your address, social insurance or tax ID number and other personal information used in the administration of your employment as an Interim Manager;

• 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 local to where you were when you contacted us;

• we may collect information for marketing purposes and analysis, including information on how you respond to email, SMS, phone and other marketing campaigns; 

• if you participate in video interviewing sessions, photos and videos of your attendance at such sessions (you will be given a chance at the session to ask not to be videoed or photographed); • details of any disabilities and any accommodations we may need to arrange for you in fulfilling your assignments as an Interim Manager; and

• in some cases we will also collect special categories of personal information where we are permitted to do so by law (so in some countries we will ask you about your background for equal opportunities monitoring), or if you include such information on your resume/CV.  NOTE: When you provide special categories of personal information on your resume/cv, you give us consent to process your resume/cv with such information.

+Why do we use personal information about you and what is our right to do so (or “legal basis”)?

We are required to have a legitimate ground or reason to process the information we hold about you.   In some cases, processing is necessary for the legitimate interests of LHH Knightsbridge.  In those cases 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).

In addition to the processing listed above, we may anonymise your personal information by processing your personal information so that it is impossible to identify any particular individuals (e.g., by removing all pieces of information which might allow an individual to be identified such as name, phone number, email address and carrying out a process to make it impossible to re-identify that individual) and use that anonymised information for any purpose.

+Do We Use Your Personal Data For Direct Marketing Purposes?

We will only send marketing communications to you, as an individual, if you have explicitly consented to us doing so. The Company does not sell, trade, rent, disclose, transfer, provide or share in any manner, your Personal Data to any third party for marketing purposes. We also will not use your Personal Data for any direct marketing purposes from us unless you give explicit consent. If you do give explicit consent, you have the right to withdraw such consent. You can withdraw consent by visiting the service portal, if such is provided for your service, or by sending us a message. Learn how to send us a message by visiting the ‘How could you contact us section.

B2B Communications. If you represent our prospect, partner or customer, either prior to entering into an agreement with LHH or during a business relationship between LHH and the legal entity which you represent, we may process your basic contact details (e.g. your name, surname, job position, company name, e-mail, and phone number) so far as necessary to carry out our joint business relationship. When we can legally do so, we may augment this information in order to assure that it is accurate. This processing of your personal data is based on our legitimate interest in maintaining and developing our business relationship and customer base, promoting our products, services, and customer loyalty programs. Generally, you cannot opt out of these sorts of communications which are not marketing related but merely required for the relevant business relationship.

You may easily opt out of receiving any further marketing communications at any time. Simply click the ‘unsubscribe’ or ‘opt-out’ function at the bottom of the email. In addition, you can also exercise your opt-out right at any time as described below. See “Contact us”.

+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 may be impossible for us to provide our services if you do not.

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

Yes, we may at times. The Company may utilize automated systems/processes and automated decision-making (like profiling) to provide you, and our clients, with the services requested 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 take into account your availability, skillset, desired salary and in some circumstances previous feedback we have received from clients to compile a shortlist which ranks those candidates who 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.  We (or our client) may also request that you undergo assessments which take into account certain attributes which may be indicative of your ability to fulfil a job requirement.

However, we do not make any automated decisions solely through automated means without implementing suitable measures to safeguard your rights, freedoms and legitimate interests.   

+For how long do we keep your personal information? 

If you are seeking recruitment services or otherwise applying for positions posted with LHH Knightsbridge, we can keep your personal information for up to 10 years after you submit your resume/CV to us for employment opportunities.  If you are seeking interim manager assignments and are successful in finding work through us, LHH Knightsbridge will retain your personal data concerning taxes, contracts of employment and any financial information (including data relating to pay, etc.) for 7 years, and other personal information for 10 years.

+Do we transfer your data to third parties?   

We usually disclose your data to third parties. This is done to complete the purposes set out above, and includes transfers to the following:

• To our suppliers. We may, for example, engage a supplier to carry out administrative and operational work in support of our relationship with you. The supplier(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 suppliers are typically IT suppliers (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 your details in order to process accounts payable and receivable). We may also engage suppliers who provide audio, video and/or web-conferencing tools, or IT technology services and solutions, which might include video interview and skills assessment tools.

• To members of the LHH group of companies in other countries.  These may be located in- or outside Canada or 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 LHH group that provide IT functions for the LHH group of companies world-wide; some of those IT functions are located in the United States and Canada.  o information is also shared with LHH Knightsbridge affiliates world-wide where you have expressed an interest in opportunities in that market and such opportunities may exist. • To other entities belonging to the Adecco Group (i.e. any companies directly or indirectly controlled by Adecco). A list of Adecco Group companies is included here

www.adeccogroup.com/worldwide-locations/ including their suppliers, contractors and agents, which may be involved in the provision of services to you. 

• To our clients/prospective employers.  We will share your data with clients of ours who are recruiting candidates for employment or interim manager assignments you may be interested in, or who are interested in your profile. These clients owe contractual and other confidentiality obligations in relation to your data to us, and to you.  These transfers may include providing to an LHH Knightsbridge client the results of reference checks requested and reports containing the results of any assessments in which you participate as required by clients with which you have made an application for employment or interim management assignments. 

• To members of the Amrop network. Amrop is a global network of recruitment companies who participate in referral arrangements.  We may transfer your personal information to Amrop members when you express interest in employment opportunity in countries in which an Amrop member operates.  

• To legal authorities. We will share your data with government, police, regulators or law enforcement agencies if required to comply with law enforcement or legal process, such as a court order or subpoena, or if needed to protect ourselves or others, for example,  individuals in a dispute or against fraud or illegal activity.  

• To other third parties in connection with corporate transactions. 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. 

Your data can be transferred and processed in one or more other countries, in- or outside Canada or the European Union. 

+For Cross Border Transfers:

When we make transfers across borders, we will ensure appropriate safeguards are in place as required, including data processing agreements, model clauses, or legal frameworks relating to the transfer of data  Regardless of where your information is processed by us or our affiliated companies, we apply the same protections described in this policy.

For residents of the European Union, Switzerland and the United Kingdom: If you are a resident of the EU, Switzerland or the United Kingdom,  your data can be transferred and processed in other countries, some of which have not yet been determined by the European Commission to have an adequate level of data protection. For example, their laws may not guarantee you the same rights, or there may not be a privacy supervisory authority there that is capable of addressing your complaints. When we engage in such transfers, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your data. To learn more about the European Commission’s decisions on the adequacy of the protection of personal data in the countries where the Company processes personal information, see this article on the European Commission website: LHH continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR. If you would like to know more about our data transfer practices or to obtain a copy of the safeguards we use to protect your data, see “Contact us” below. 

In the case of transfers to the United States, LHH Knightsbridge’s affiliate in the United States, Lee Hecht Harrison LLC (“LHH US”), complies with an intragroup data transfer agreement incorporating the substance of the EU model clauses as well as the principles of the E.U.-U.S. and the Swiss-U.S.

Privacy Shield Framework (the “Privacy Shield Principles”) as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, Switzerland and the United Kingdom to the United States, respectively. LHH US has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/. 

LHH US commits to resolve complaints about your privacy and our collection or use of your personal information.   LHH US has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of a complaint directed to us, or if we do not satisfactorily address your complaint, please visit www.bbb.org/EUprivacy-shield/for-eu-consumers/ for more information and to file a complaint.  

Please note that if your Privacy Shield complaint is not resolved through the above channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. 

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, LHH is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Please note that, despite the Court of Justice of the European Union’s invalidation of the EU-US Privacy Shield Framework as a mechanism for transfers of personal data between the EU and the U.S. in Case C-311/18, LHH intends to maintain its self-certification under the EU-US Privacy Shield Framework and remains committed to complying with the Privacy Shield Principles. For more information one the U.S. Department of Commerce’s continued administration of the Privacy Shield program, please visit https://www.privacyshield.gov/article?id=EU-U-S-Privacy-Shield-ProgramUpdate.

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 can ask us to provide you with an electronic copy of your information.  Please note that there may be certain categories of information which LHH is legally unable to provide access to. If LHH declines to provide access to any of the Personal Data you request, you will be provided with the reasons for such a decision.

• 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.  

• 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 is deleted. You may make such a request at any time and LHH Knightsbridge 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, LHH Knightsbridge will do so without undue delay. Please bear in mind, once your data is deleted LHH Knightsbridge might not be of service to you anymore. If you want to re-register with the company again, you will need to provide us with your data. 

• Right to object 

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

• Right to restrict

In certain circumstances, you have the right to restrict the processing of your Personal Data. However, in some instances, such restriction of processing may limit the services that you can receive from us.

*All requests are subject to applicable law. In accordance with applicable law, we  will take steps to verify your identity and the request before processing any request, including, for example, requiring you to provide identifying information about yourself, your account, your prior interactions with us, and/or such other additional information as may be required by law.

If you want to exercise any of your rights, click here.

Finally, we are committed to working with you to obtain a fair resolution of any complaint or concern about the processing of your Personal Data. If, however, you feel we have not addressed your complaints, 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. 

CALIFORNIA RESIDENTS: Under California Civil Code Section 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information, if any, which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a written copy of this notice, please submit to us, click here.

+What about data security when you are using LHH Knightsbridge Systems?

You are responsible for keeping your login details to our Portal(s) 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 could you contact us?

If you have any questions or concerns regarding our Notice, would like further information about how we protect your information (for example when we transfer it outside Canada or the EU) and/or when you want to contact the company’s Global Data Privacy Lead, please contact us by clicking here, or by mail to our Global Data Privacy Lead at the address below:

Lee Hecht Harrison LLC  2301 Lucien Way, Suite 325  Maitland, Florida 32751 USA  Attn: Global Data Privacy

+How do we handle changes to this Notice?

The terms of this Notice may change from time to time. We shall publish any material changes to this Notice through appropriate notices either on this website or contacting you using other communication channels.  Below will always show the last update to the Privacy Notice and will show you the history of changes.

LAST UPDATED: [●] 1 September 2020