This Policy covers information O’Neill Consulting collects in connection with our recruitment services (“Services” or “Service”). This Policy also covers information collected through:
- web sites we operate from which you are accessing this Policy (the “Site”),
- the software applications we make available for use on or through computers or mobile devices (the “Apps”),
- our social media pages and apps to which the Site links (collectively, our “Social Media Pages”), and
- HTML-formatted email messages we send to you that link to this Policy (collectively, including the Site, Apps, and our Social Media Pages, the “Online Systems”)
This Policy also covers other means by which we collect information. For example, it also covers how we collect information from in person discussions, telephone conversations, and through non-electronic communications (i.e., collection through other means than our Online Systems).
Personal Information we collect
O’Neill Consulting collects information that identifies you as an individual or relates to an identifiable individual (“Personal Information”) to provide Services to you, to our clients, and to operate our business. The type of Personal Information we collect about you depends on the situation at hand.
- We may collect your name, contact details and your preferred means of communication. We may also collect your responses to survey and assessment questions.
- In the course of our Recruitment Services, we may collect the following types of information about you as a potential candidate: name, address, telephone number, e-mail address, resume information (employment history, education, professional credentials, memberships in professional organizations, skills, etc.), citizenship, information from former employers and other references, and additional information to the extent we have acquired or you have provided us with such information. We also use photos of you that you provide to us or that you make publicly available on the Internet (e.g., LinkedIn).
- Where permitted by law, we may collect compensation and benefits information about you to consult with you or our clients on rewards and benefits.
- As permitted by applicable laws, we obtain background verification information. We encourage you not to provide any other sensitive Personal Information to us, such as government identification numbers, payment card numbers, information related to racial or ethnic origin, political opinions, religious or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership.
As you work with us, you provide some Personal Information directly to us. We may collect Personal Information when you submit a resume, respond to employment opportunities, answer online assessment questions, provide information about yourself to our consultants or contact us via e-mail, electronic forms, or telephone.
If you submit any Personal Information about other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy.
Personal Information about you may also come from our clients to whom we provide Services. We may also obtain Personal Information about you from third parties. When someone participates in a search process with us, they may share Personal Information about you.
When providing Services, we may also obtain Personal Information about you from referrals, networking activities, public databases, joint marketing partners, licensed databases, and social media platforms.
We also collect Personal Information about you from third parties, including, for example, when a fellow candidate or reference provides information about you, when a colleague recommends that we consider you for a position or from other sources such as public databases, joint marketing partners and social media platforms.
How we use the Personal Information we collect
The following paragraphs describe the ways in which we may use your Personal Information:
Fulfilling your requests. We use your Personal Information to respond to your inquiries and fulfill your requests. If you contact us, we keep a record of your contact information and correspondence, and we use information you provide in your message to respond to your inquiry. We do so to manage our contractual relationship with you.
Business purposes. We use Personal Information to render Services to you and our clients. We do this to fulfill our contractual relationships with you and our clients and where we have legitimate, beneficial interest in using Personal Information to conduct our business.
Informational communications. We may use your Personal Information to send you information or marketing materials. O’Neill Consulting sends informational e-mails, articles, white papers, proposals, contractual agreements, and information regarding our Services. We also use your Personal Information to conduct surveys. We do so either with your consent or because we have a legitimate beneficial business interest.
We may retain and use Personal Information about you for research, publication, development, benchmarking, longitudinal studies, trend analysis, to improve and enhance our Services, or to develop and market new Services. We may use Personal Information about you to ensure that our Services conform with legal requirements like equal opportunity laws.
Occasionally, we may desire to use your Personal Information in press releases and direct marketing materials. Before we use your Personal Information in that way, we will obtain consent from you.
Administrative information. We use your Personal Information for our business purposes, such as internal communication regarding candidates and clients, determining the effectiveness of our promotional activities, administering our Services, and for procurement and financial transactions. We may also contact you to verify that the Personal Information we collected about you is accurate and current. We use the Personal Information to manage our contractual relationship with you or to comply with a legal obligation.
Other activities. In addition, we may use and disclose Personal Information in other ways to perform our Services, as described below:
- We may use Personal Information that we have collected to create a profile about you, which may be used to identify professional opportunities we think may be of interest to you. We may contact you from time to time regarding those opportunities.
- You can always object to our creating a profile about you. If you object, we will remove your profile from our database, but this will also mean that you will not be considered for current or future opportunities.
- We may also contact individuals from time to time for referrals. We may solicit names of, or additional Personal Information regarding, potential candidates in connection with our Services to understand the market and provide other consulting services to our clients. We also use your Personal Information to confirm references and conduct education and background checks where legal and as appropriate.
Analytics. We may use Personal Information to conduct analytics and thought leadership materials. Any published product will refer only to larger aggregations of individuals and will not identify you personally or include any results attributable to you as we may anonymize, aggregate or de-identify Personal Information so the end-product does not identify you or any other individual. Such aggregated, anonymized, or de-identified information is not considered Personal Information for purposes of this Policy, and we may use it for any purpose. We perform analytics because we have a legitimate beneficial business interest in doing so.
Anonymized or de-identified data. Additionally, we may aggregate (anonymize) or de-identify Personal Information in such a manner that the end-product does not personally identify you or any other individual, for example, to identify trends by industry, geography, level, etc., compile reports, and publish journal articles to further the knowledge base of organizational and leadership science. Such aggregate or de-identified information is not considered Personal Information for purposes of this Policy and we may use it for any purpose.
Who has access to your Personal Information
Disclosure to clients. In the course of our Services, we disclose Personal Information regarding candidates, including the results of assessments and related data, to prospective employers that have engaged O’Neill Consulting to fulfill search requests, or to reference sources.
Disclosure to affiliates. We may share Personal Information with our affiliates to provide seamless Services for you and our clients. We are responsible for managing jointly-used Personal Information.
Disclosure to service providers. O’Neill Consulting works with third parties who provide services that may include, but are not necessarily limited to, assessment tools, including assessment validation services; website hosting and IT consulting services; data analysis; resume verification; education verification; background checking; payroll services; public relations services; attorneys, accountants, and other administrative and back-up and security services. As part of providing those services, such third parties may be provided with access to Personal Information.
Business transfers. O’Neill Consulting may disclose or transfer any and all Personal Information to a third party in connection with a strategic alliance with such third party, or in the event of a sale of our company or one of our affiliates, or a merger or consolidation involving our company or one of our affiliates, or a sale or transfer of assets or of any portion of our business or the business of one or more of our affiliates.
Other disclosures. O’Neill Consulting may also use or disclose Personal Information (to comply with a legal obligation of because we have a legitimate interest to do so) in order to:
- comply with applicable laws;
- respond to inquiries or requests from public or government authorities, including those outside of your country of residence;
- protect the rights, privacy, safety or property of O’Neill Consulting and our affiliates, you or others;
No assumption of liability. We cannot and do not assume any responsibility for the actions or omissions of third parties, such as clients, including the way they use Personal Information received either from us or from other or from other independent sources.
Other Information we collect
O’Neill Consulting collects Other Information that does not reveal your specific identity (“Other Information”), such as:
- Information collected through cookies, pixel tags, and other technologies
- Demographic information and Other Information provided by you
- Aggregated information
Since Other Information does not reveal your specific identity, we may use it for any purpose. If we combine any Other Information with Personal Information that identifies you directly (such as combining your name with your location), we will treat the combined information as Personal Information as long as it is combined.
If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose your Personal Information as detailed in this Policy.
We and our third-party service providers may collect Other Information in a variety of ways.
O’Neill Consulting is committed to continuously improving the Site experience for our visitors. Therefore, we collect aggregate data about our visitors such as page views, visitor frequency, Internet browser usage, and length of time spent on the Site. This information is analyzed internally to understand the effectiveness of our Site.
O’Neill Consulting may from time to time sponsor special features or promotions on the Online Systems and additional privacy information may be posted. Depending on the nature of the Service being utilized or your location, you may be asked to consent to the collection, use, transfer, and disclosure of your Personal Information. You may also be shown a privacy notice before participating in a Service. That privacy notice, to the extent it conflicts with this Policy, will govern that particular Service, feature or promotion.
Choice and access
Your provision of Personal Information to us is voluntary, although if you do not provide certain Personal Information you may not be able to participate in our Services.
You may contact us at email@example.com if you would like to:
- ask questions about how we handle your Personal Information,
- withdraw your consent to our use of your Personal Information,
- we will make reasonable attempts to delete Personal Information upon your request.
- object to our use of your Personal Information for our legitimate business interests, or
- request an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law),
- request to review, correct, update, suppress or restrict the use of your Personal Information,
- Although we strive to maintain accurate Personal Information, if it is determined the Personal Information is not accurate, we will work quickly to correct it.
If you would like to opt-out of receiving marketing communications from us, please contact us at firstname.lastname@example.org to have your contact information removed from our marketing databases.
You can also forward a copy of the e-mail or marketing communications from which you want to opt-out.
For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will comply with your request as soon as reasonably practical and may need to contact you to be sure that we understand your request.
We also may need to retain certain Personal Information about you such as your e-mail address to honor opt-out or similar requests. Please keep in mind that this residual Personal Information will remain within our databases, access logs, and other records, which may or may not contain identifiable Personal Information about you. The residual Personal Information will not be used for commercial purposes. However, O’Neill Consulting reserves the right, from time to time, to recontact former users of its Services as appropriate.
Location of Personal Information collected and maintained
Depending on the Service we are providing to you, your Personal Information may be collected, used, processed, disclosed, and transferred to and within the United States and other countries where we have contractual relationships with our clients. By using our Online Systems or Services, you understand that your Personal Information may be transferred to countries outside of your country of residence, which may have different data protection rules than your country.
O’Neill Consulting has reasonable organizational, technical and administrative measures in place to protect against the loss, misuse and alteration of Personal Information about users of the Online Systems which is under our control. Unfortunately, however, no security system, or system of transmitting Personal Information over the Internet can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at email@example.com.
We will retain your Personal Information for the period necessary or permitted, considering the purpose(s) for which it was obtained. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you or our client (e.g., for as long as you have a profile with us or keep using the Services),
- A period beyond the time of the ongoing relationship if we have a legitimate internal operations need, such as a need to retain such information for analysis and record-keeping,
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them), or
- Whether retention is advisable considering our legal position (such as regarding applicable statutes of limitations, litigation or regulatory investigations).
Links to other websites
This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any other third parties. On the Online Systems, you may have the opportunity to follow a link from or to other websites maintained by O’Neill Consulting affiliates or other third parties. The inclusion of a link on our Online Systems does not imply our endorsement of the linked site. Because these other websites may not be hosted or controlled by O’Neill Consulting, this Policy does not address the privacy practices of those websites. We encourage you to review the privacy policies of each of those websites.
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as LinkedIn, Facebook, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.
Use of online systems by children
The Online Systems are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide their Personal Information through the Online Systems.
Updates to this policy
This Policy is subject to change from time to time as O’Neill Consulting reviews its privacy practices. You can determine the effective date of policy by checking the “Last update” legend at the bottom of the Policy.
Summaries of policy
This Policy is the sole authorized statement of O’Neill Consulting’s practices with respect to the online collection of Personal Information through the Online Systems and the usage of such Personal Information. Any summaries of this Policy generated by third party software or otherwise shall have no legal effect, are in no way binding upon O’Neill Consulting, shall not be relied upon in substitute for this Policy, and neither supersede nor modify this Policy.
Questions regarding this Policy should be directed to O’Neill Consulting at firstname.lastname@example.org.
Last update: November 30, 2018