Privacy Notice

This Notice is issued by each of the Controller entities listed at: https://www.mercuriurval.com/global/contact/find-us/ (together, “Mercuri Urval”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including members of our professional network, candidates, project participants, clients, visitors to our Sites, other users of our services, personnel of clients and vendors, and visitors to our premises (together, “you”). Defined terms used in this Notice are explained in Section (R) below.

We understand that your privacy is important. This Notice describes how we Process and protect your Personal Data in connection with our various business activities, the purpose of our Processing and your rights when choosing to let Mercuri Urval Process your Personal Data.

This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.

This Notice was last updated on: 2024-02-08.

We collect or obtain Personal Data about you from the following sources:

• Data provided to us: We obtain Personal Data when those data are provided to us (e.g., where you are added to our professional network of clients, business contacts, and candidates, when you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).
• Data we obtain in person: We obtain Personal Data during meetings, at trade shows, during visits from sales or marketing representatives, or at events we attend.
• Collaborations: We obtain Personal Data when you collaborate with us in research or in an advisory/consultancy capacity.
• Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your employer).
• Data you make public or we retrieve from publicly accessible sources: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post), or we retrieve from publicly accessible sources.
• Site data: We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
• Registration details: We collect or obtain Personal Data when you use, or register to use, any of our Sites, or services.
• Content and advertising information: If you interact with any third party content or advertising on a Site (including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.
• Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., business information aggregators, references from past employers; records from academic institutions; etc.).

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, or services, including where those data are collected from different devices.

We Process the following categories of Personal Data about you:

• Personal details: given name(s); preferred name; and photograph.
• Contact details: correspondence address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
• Professional details: your CV; records of your experience and expertise; professional history; compensation and benefits information; information about your experience; participation in meetings, seminars, advisory boards and conferences; information about your professional relationship with other individuals or institutions; language abilities; and other professional skills; and a record of your and your company’s history with Mercuri Urval.
• Survey and testing data: records of surveys, testing and assessments undertaken; records of feedback from surveys, testing and assessments; records of progress; and analysis of suitability for general or specific roles with clients.
• Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
• Visitor logs: records of visits to our premises.
• Consent records: records of any consents you have given, together with the date and time, means of consent, and any related information (e.g., the subject matter of the consent).
• Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.
• Data relating to our Sites: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; username; password; security login details; usage data; and aggregate statistical information.
• Employer details: where you interact with us in your capacity as an employee of a third party; and the name, address, telephone number and email address of your employer, to the extent relevant.
• Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
• Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

• Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
• Establishment, exercise or defence of legal claims: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal claims; or
• Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). This may include cognitive tests, personality tests, background checks, criminal records checks, and Processing of feedback from interviews, surveys, tests or assessments, as detailed in this Notice.

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

The purposes for which we Process the categories of Personal Data identified in Section (D) above, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

We disclose Personal Data to other entities within the Mercuri Urval group, for legitimate business purposes and the operation of our Sites, or services to you, in accordance with applicable law. In addition, we disclose Personal Data to:

• you and, where appropriate, your appointed representatives;
• our clients in order to provide our services to them and you;
• legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• accountants, auditors, consultants, lawyers and other outside professional advisors to Mercuri Urval, subject to binding contractual obligations of confidentiality;
• third party Processors (such as payment services providers; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);
• any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;
• any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
• any relevant third party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
• any relevant third party provider, where our Sites use third party tools, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

Because of the international nature of our business, we transfer Personal Data within the Mercuri Urval group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Notice. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your Personal Data from the UK or the EEA to recipients located outside the UK or the EEA (as applicable) who are not in Adequate Jurisdictions, we do so on the basis of Standard Contract Clauses or Intra Group Data Transferring Agreements. You are entitled to request a copy of these documents using the contact details provided in Section (Q) below.

Please note that when you transfer any Personal Data directly to any Mercuri Urval entity established outside the UK or the EEA (as applicable), we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Notice

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

We take every reasonable step to ensure that:

• your Personal Data that we Process are accurate and, where necessary, kept up-to-date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time, we may ask you to confirm the accuracy of your Personal Data.

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:

(1) we will retain Personal Data in a form that permits identification only for as long as:

(a) we maintain an ongoing relationship with you (e.g., where you are a candidate in our Executive Candidate Network); or

(b) your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between us and your employer, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

and:

(2) in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

Once the periods in paragraphs (1), and (2) above, each to the extent applicable, have concluded, we will either:

• permanently delete or destroy the relevant Personal Data; or
• anonymize the relevant Personal Data.

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

• the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
• the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
• the right to request rectification of any inaccuracies in your Relevant Personal Data;
• the right to request, on legitimate grounds:
  • erasure of your Relevant Personal Data; or
  • restriction of Processing of your Relevant Personal Data;
• the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
• where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
• the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, in relation to the UK, the Information Commissioner’s Office (https://ico.org.uk/) or in relation to the EU, the Data Protection Authority for EU Member State in which you live, or in which you work, or in which the alleged infringement occurred (see the list here: https://edpb.europa.eu/about-edpb/about-edpb/members_en), each if applicable).

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

• the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such Processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR / UK GDPR; and

• the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (Q) below. Please note that:

• in some cases, it will be necessary to provide evidence of your identity before we can give effect to these rights; and
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

When you visit a Site we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We Process Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy.

All use of our Sites, or services is subject to our Terms of Use. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

For the purposes of this Notice, the relevant Controllers are listed at https://www.mercuriurval.com/global/contact/find-us/  

Our Data Protection Officer’s contact details are:

Name: Lene Juul Pedersen
Email: gdpr.int@mercuriurval.com
Phone: +45 50707048