The CEB Talent Measurement Solution

Data Protection Notice

Please read this Data Protection Notice ("Notice") to continue

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.

This Notice describes how SHL US LLC of 111 Washington Avenue S, Suite 600, Minneapolis MN 55401, USA, United Kingdom, and its affiliates and (together, "SHL" or "we" or "us") collect and use personal and non-personal information collected through our assessment products and services. When we refer to personal information, we mean information about you, where we may be able to identify you ("Personal Information").

This Notice applies to assessment takers, whether such assessments are carried out online or in any other format.

Please read the entire Notice carefully - by taking an assessment, you consent to its terms (including as amended from time to time). If you do not agree with the terms of the Notice, you should not take the assessment.

If you have questions about the Notice, please contact us at dataquestions@shl.com.

Information We Collect

Personal Information we collect on behalf of the Employer: If you have been asked to take an assessment by your employer or potential future employer (the "Employer"), that Employer will be the data controller of your Personal Information as described below. Depending on the type of assessment and the instructions we receive from the Employer, the Personal Information that we collect and process on the Employer's behalf may include:

- Your name and email address or other personal details ("Candidate Data");

- Your answers to the assessment questions ("Assessment Data");

- Your assessment results ("Results Data"); and

- Additional information provided by the Employer about you (e.g., CV or resume information, whether you were hired or performance appraisals) ("Employer Provided Data").

As the data processor, we will hold the above mentioned data in accordance with the Employer's instructions and may use such data for subsequent assessments and/or reports, as instructed by the Employer.

Optional Personal Information we may collect:In some cases, at the beginning of an assessment, we may ask you to answer some optional research questions by providing certain types of demographic information for research purposes ("Research Data"). Providing this information is completely optional - if you do not want to answer a question, simply select the "Prefer not to answer" option. If you choose not to answer these questions, it will not keep you from taking the assessment or affect the results of the assessment in any way. This data will be used only in an anonymised format for research purposes (described below) and will NOT be provided to the Employer. We will be the data controller of this Optional Personal Information.

Technical Information: In addition to the Personal Information described above, we also collect information related to the system ("Technical Information") used to take the assessment, including information about browser types, operating systems, IP addresses, and date/time stamps.

How We Use Your Information

We will compile a report containing the Results Data, potentially combined with the Employer Provided Data (both described above) and/or Benchmark Data (as described below) which will be given to the authorised representatives of the Employer ("Report Data").

We may use an anonymised combination of your Assessment Data, Results Data, Employer Provided Data, and Research Data (where provided) for the following purposes:

- To develop and improve our assessments and services we offer;

- To ensure that our assessments remain fair and objective and to prevent unfair discrimination;

- To create aggregate benchmark measurements against industry-recognised differences for particular groups, jobs, and industries ("Benchmark Data").

We may disclose aggregated and anonymised results of our research to third parties. This information will not identify any individual or organisation.

Where We Process Your Information

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.

Disclosures to Third Parties

When we have the appropriate permissions, we may disclose Personal Information to third parties in the following limited circumstances:

  • if we contract with third parties to perform or provide certain services on our behalf (in which case those third parties will be contractually required to only use the data for purposes of performing those services);
  • if we are under a legal obligation to disclose Personal Information; or
  • If we sell any business or assets (in which case the buyer will be obligated to honour the terms of this Notice).

Protecting Your Personal Information

We take appropriate steps to protect Personal Information. We have appropriate technical, administrative, and physical security controls in place to protect Personal Information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss.

Access to your Personal Information

If you took an assessment at the request of an Employer, please contact that Employer directly if you would like access to your Personal Information or to exercise any of your other rights that you may have in relation to your Personal Information.

When we are the data controller of your Personal Information, you may contact us in order to find out what information we hold about you or to access,cancel or correct any information that we hold about you. You may request access to your information as mentioned above by printing and completing a Subject Access Request Form and sending it back to us via post or email. The purpose of this form is to ensure that you give us all the necessary information to enable us to comply with your request. You do not have to use this form, but if you do not, we encourage you to provide all the information requested on the form with your request.

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 or how we process your personal information, please email us at dataquestions@shl.com.

We agree that any disputes regarding our data protection policies and related actions regarding Personal Information from Europe can be heard by the European Data Protection Authorities or the Swiss Federal Data Protection and Information Commissioner, and we will be subject to the determinations of those bodies. Formal complaints regarding our data protection practices and related actions regarding Personal Information from countries outside the EU may be addressed directly to the data protection authority in your country.

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 authorised to take assessments on our systems. Please contact us at dataquestions@shl.com with any questions.