This privacy policy applies to the operations of Witt/Kieffer Ccentric Limited (Witt/Kieffer Ccentric), and where searches are carried out jointly with Witt/Kieffer Ccentric and one or both parent companies, Ccentric Holdings Pty Limited in Australia and Witt/Kieffer, Ford, Hadelman, Lloyd Corp in the United States.

Witt/Kieffer Ccentric recognises the importance of privacy in relation to personal information of candidates and others. The Data Protection Act 1998 (United Kingdom) (DPA) and any other relevant legislation, including but not limited to the Privacy Act 1988 (Cth, Australia) (Australian Privacy Act) and the Personal Data Protection Act 2012 (Singapore) (PDPA), collectively the (Privacy Acts), apply to Witt/Kieffer Ccentric’s collection, use, disclosure and storage of your personal information. For the purpose of the DPA, the data controller is Witt/Kieffer Ccentric of Level 10, 88 Wood Street, London EC2V 7RS.

This privacy policy outlines how Witt/Kieffer Ccentric manages personal information and will be made available to any person upon reasonable request.

Personal information

For the purposes of this policy, “personal information” means information or an opinion about an identified person, or a person who is reasonably identifiable, from that data or from that data and other information to whichWitt/Kieffer Ccentric has or is likely to have access:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.

– Personal information may also include information collected from you during, for the purpose of and as a result of the recruitment process in a number of ways including through your resume, reference checking, verification of educational qualifications and/or professional membership, reference data, results of psychometric and medical tests and results of background and reference checks as well as any other personal information obtained by Witt/Kieffer Ccentric in connection with your possible candidature for a position.

Where Witt/Kieffer Ccentric is providing leadership consulting services, the types of personal information it may collect about you for the purpose of providing these services include results of psychometric testing, information collected in 360˚ feedback surveys, individual and/or team assessments and development programs.

Sensitive information

For the purposes of this policy, “sensitive information” means personal information about a person’s:
(a) racial or ethnic origin; or
(b) political opinions; or
(c) membership of a political association; or
(d) religious beliefs or affiliations; or
(e) philosophical beliefs; or
(f) membership of a professional or trade association; or
(g) membership of a trade union; or
(h) sexual orientation or practices; or
(i) criminal record;
(j) health information about a person; or
(k) genetic information about a person that is not otherwise health information; or
(l) biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
(m) biometric templates.

“Sensitive personal data” (as defined in the DPA) shall have the same meaning as “sensitive information” referred to above.

Privacy principles

Witt/Kieffer Ccentric will follow the privacy principles set out below:

Collection

Witt/Kieffer Ccentric may collect information about you in various ways, including by way of dealing with you in person, over the telephone, via video link, through its website, www.wittkiefferccentric.com, over an email server, by conducting reference checks and background checks with third parties (including checks to verify educational qualifications, relevant professional membership or working rights) or through customer feedback or survey forms.

Personal information: Witt/Kieffer Ccentric will only collect personal information about you to the extent that it is reasonably necessary to do so for one or more of Witt/Kieffer Ccentric’s functions or activities as a global executive search and leadership consulting firm.

Sensitive information: Witt/Kieffer Ccentric will only collect sensitive information about you with your consent and, again, only where collection is reasonably necessary for one or more of Witt/Kieffer Ccentric’s functions or activities as a global executive search and leadership consulting firm, or where collection of the sensitive information is required or authorised by or under a relevant law or a court/tribunal order, or where a “permitted general situation” or a “permitted health situation” exists, as defined under the Privacy Acts.

Witt/Kieffer Ccentric will only ask for information from you by fair and lawful means. In the case of personal information that Witt/Kieffer Ccentric asks for, we will collect personal information directly from you unless it is unreasonable or impracticable to do so (which will include, for example, circumstances where Witt/Kieffer Ccentric obtains personal information about you from a third party referee for the purpose of conducting a reference check, or where Witt/Kieffer Ccentric obtains personal information about you through results of psychometric testing, information collected in 360˚ feedback surveys, individual and/or team assessments and development programs).

In the case of unsolicited personal information, Witt/Kieffer Ccentric will treat the personal information in accordance with the Privacy Acts.

Notification of collection

You will be told when Witt/Kieffer Ccentric collects personal information by way of a Privacy Collection Statement. In the Privacy Collection Statement, you will be notified of the purpose of the collection, your rights to access your personal information, the fact that your personal information will be shared amongst Witt/Kieffer Ccentric, its parent companies Ccentric Group in Australia [and Singapore] and Witt/Kieffer in the United States where a joint search is being conducted and with potential employers in the country where they the new employment position is located, and what will happen (if anything) if you do not give the information to Witt/Kieffer Ccentric.

Use and disclosure

Your personal information may be disclosed to employees of all Witt/Kieffer Ccentric companies, which are related bodies corporate which means our subsidiaries, our ultimate holding company and its subsidiaries (as defined in the UK Companies Act 2006) and to Witt/Kieffer Ccentric’s service providers, for the purposes described in this privacy policy.

Generally speaking, Witt/Kieffer Ccentric will use or disclose personal information for the primary purpose for which it is collected, being your possible placement by Witt/Kieffer Ccentric into a new employment position.

Witt/Kieffer Ccentric may also use your personal information for secondary purposes related to the primary purpose, which could include: analysis of test results (including medical tests and assessments); identification of training needs; workplace rehabilitation; management of any complaint, investigation or inquiry in which you are involved; or client/candidate business relationship management. Witt/Kieffer Ccentric will also use or disclose personal information for a secondary purpose in circumstances where Witt/Kieffer Ccentric has obtained your consent to such use or disclosure, where use or disclosure is required or authorised by or under a relevant law or a court/tribunal order, or where a “permitted general situation” or a “permitted health situation” exists, as defined under the Privacy Acts.

Witt/Kieffer Ccentric may also disclose your personal information to third parties (i) in the event that Witt/Kieffer Ccentric sells or buys any business or assets, in which case your personal information may be disclosed to the prospective seller or buyer of such business or assets; or (ii) if Witt/Kieffer Ccentric or substantially all of its assets are acquired by a third party, in which case your personal information may be one of the assets transferred.

Witt/Kieffer Ccentric will also inform you of your right to privacy during the recruitment process by taking a range of steps, including by:

a) sending you an acknowledgement of written personal information collected (e.g. a candidate’s resume);

b) inform you of Witt/Kieffer Ccentric’s privacy policy as part of the communication relating to a specific job application process;

c) taking reasonable steps not to disclose candidate resumes to a third party except with the consent of the candidate or in exceptional circumstances permitted under the Privacy Acts.

Direct marketing: Witt/Kieffer Ccentric will not use or disclose sensitive information about you for the purpose of direct marketing unless such disclosure is permitted under the Privacy Acts. In the case of personal information which is not sensitive information and which Witt/Kieffer Ccentric has received directly from you, Witt/Kieffer Ccentric may use and disclose such information for the purposes of sending you a newsletter or other information related to Witt/Kieffer Ccentric’s business or activities. Witt/Kieffer Ccentric will not send you these communications if you choose to opt out by contacting Witt/Kieffer Ccentric at any time by way of an opt out option contained in such communications. Witt/Kieffer Ccentric will only disclose sensitive information about you with your consent.

Witt/Kieffer Ccentric will disclose your personal information to third parties outside of the Witt/Kieffer Ccentric where it is required to do so in order to carry out identity and qualification verification checks through third party providers (which might include proof of identity checks, police checks, right to work checks and psychometric testing).

Quality of personal information

Witt/Kieffer Ccentric will take reasonable steps in the circumstances to facilitate the personal information it collects being accurate, complete and up to date.

Security of personal information

Witt/Kieffer Ccentric will take reasonable steps in the circumstances to protect the personal information it collects from misuse, loss, and unauthorised access, modification or disclosure.

Access and correction

Access: Subject to applicable exceptions set out in the Privacy Acts (including where access would pose a serious threat to the life, health or safety of a person), Witt/Kieffer Ccentric provides the opportunity for candidates to view and obtain a copy of personal information that Witt/Kieffer Ccentric has collected about them.

In some circumstances, Witt/Kieffer Ccentric may seek payment for reasonable costs incurred in supplying you with this information but the charges will not apply to the making of the request itself. Please be prepared to sufficiently identify yourself with photo ID prior to viewing any of your personal information.

Correction: If you ask Witt/Kieffer Ccentric to correct any of your personal information (for example if your personal information is not accurate or your personal information changes), Witt/Kieffer Ccentric will take such steps (if any) as are reasonable in the circumstances to correct or update the personal information. As this procedure could involve retrieving information from storage or archives, please allow up to one week for your request to be actioned. Witt/Kieffer Ccentric may also contact you from time to time to update your details. Witt/Kieffer Ccentric will not charge you for the cost of making a request or for the cost of correcting the personal information.

If Witt/Kieffer Ccentric is unable to agree that the personal information it holds about you is accurate, complete and up to date, you may ask Witt/Kieffer Ccentric to place with the information, a statement by you claiming that the information is not accurate, complete and up to date (indicating that the correction was requested but not made). Witt/Kieffer Ccentric will not charge you for the cost of making of the request or for the cost of associating the statement with the personal information.

Identifiers

If required under the Privacy Acts, except in exceptional circumstances which are outlined in the Privacy Acts, Ccentric will use Commonwealth Government identifiers for the purpose for which they were issued and will not adopt its own identifiers of a person except where this is necessary to carry out Witt/Kieffer Ccentric’s activities or functions.

Anonymity and pseudonymity

To the extent required under the applicable Privacy Acts, wherever lawful and practicable, Witt/Kieffer Ccentric will give you the option of not identifying yourself, or of using a pseudonym. However, please note, the nature of the recruitment, executive placement and leadership consulting services which Witt/Kieffer Ccentric provides means that in most cases it will not be possible to preserve anonymity and pseudonymity.

Cross border disclosure of personal information

Witt/Kieffer Ccentric may disclose personal information to overseas recipients where permitted under the Privacy Acts.

In these circumstances, personal information will be disclosed to Witt/Kieffer Ccentric’s related bodies corporate and business associates located in Australia, Singapore, and the United States of America. From time to time, the nature of the placement may mean that your personal information is disclosed to a recipient in a jurisdiction not listed in this privacy policy (for example, to the client employer in the jurisdiction where the role is located or the jurisdiction where the HR or decision-making function of a client employer is located).

Subject to any applicable exceptions set out in the Privacy Acts, Witt/Kieffer Ccentric will only transfer personal information to an overseas jurisdiction in circumstances where you consent to the transfer to such jurisdiction and/or the information will have an appropriate level of protection.

By submitting your personal information and/or applying for a role, you agree and consent to this transfer, storing or processing.

Complaints regarding personal information

Complaints about a breach of the Privacy Acts, including the Privacy Principles under the Privacy Acts, may be made to Witt/Kieffer Ccentric’s Privacy Coordinator. Contact details are as follows:

Witt/Kieffer Ccentric
Level 10, 88 Wood St
London EC2V 7RS
United Kingdom
Email: privacy@wittkiefferccentric.com

Variation

Witt/Kieffer Ccentric reserves the right to vary this privacy policy at any time and will publish all updated versions on its website, http://www.wittkiefferccentric.com.