CONFIDENTIALITY

Privacy Policy for Processing Personal Information

Scalable Global Solutions JSC., its affiliated entities, branches and associates throughout the world (hereinafter collectively “Scalable Global Solutions JSC.”) have implemented this firm-wide data privacy policy to create a consistent and uniform approach to processing Personal Information (i.e., any information relating to an identified or identifiable natural person (“data subject”)) we have on individuals for executive search and assessment and related purposes. (For details about our structure and addresses, a list of our offices worldwide, executive and board search and assessment practices, and more about the firm, please visit our Web site at (www.sgs-daas.com). This Privacy Policy establishes data protection rules that apply to all our offices worldwide, subject to applicable local laws, including but not limited to data protection laws.  It is the minimum set of rules an office is required to follow.

 

Information Collection

Scalable Global Solutions JSC. collects information in the course of its work in order to be able to provide services to our clients as an executive search and assessment firm. Typically, this information comprises what is included in a standard curriculum vitae/résumé, (e.g., name, address, and telephone number, e-mail address, employment history, degrees and other qualifications, languages and other skills). It also may include interview notes, comments from third parties and a record of our contacts with individuals. Our records may derive from information collected directly from the data subject, that is publicly available, as well as information gained from third-party sources.  We make every effort to ensure that any information held is accurate and kept as up-to-date as possible. We do not obtain information under false pretences.

As a matter of policy, we do not process sensitive information (e.g., data on racial/ethnic origin, health, sexual orientation, political opinions, criminal records, religious or philosophical beliefs, trade union membership). If such information is processed or transferred, it will only be done when and to the extent legally permitted and, as the case may arise, with the data subject’s explicit and unambiguous consent or when the data subject has made this information public (unless prohibited by applicable law).

To the extent permitted under applicable law, by providing any information to us, the data subject will be deemed to have given explicit consent for us to hold and use such information.

 

Use and Disclosure of Personal Information

We maintain Personal Information in our proprietary database. In order to provide a truly international service, our proprietary database is accessible to all Scalable Global Solutions JSC. offices worldwide. Only Scalable Global Solutions JSC. employees or agents may access this database, which is used only for the purposes of executive search, assessment and related purposes. We review Personal Information we have in our database to identify individuals to recruit for clients seeking to fill specific senior-level executive positions. (Please visit our Web site for more information on our clients and the services we provide.)

Personal Information can be used for the purposes of carrying out the tasks related to our executive search and assessment practices, including, but not limited to, evaluating prospects’ qualifications, contacting potential candidates, verifying information and communicating with clients about a specific position.   To carry out these tasks, we inform our clients of the background and skills, as well as other relevant Personal Information, of those individuals who are distinctly qualified to be considered candidates.

 

Other Uses

Scalable Global Solutions JSC. may also use Personal Information for quality improvement purposes, such as training and systems maintenance. In the normal course of business, we may also develop and disclose (in an anonymous format) statistical data derived from the Personal Information we maintain. It is the policy of Scalable Global Solutions JSC. never to disclose Personal Information to third parties for direct marketing services.  Should the policy change, consent from the data subject will be obtained to make such a disclosure.

 

Where and to whom Personal Information May Be Disclosed

Scalable Global Solutions JSC. may engage third parties to provide specific services, including, but not limited to, auditing for compliance with relevant regulations; and providing legal advice, translations, résumé formatting, back-up and security services and searches, and research and administrative services. Accordingly, for the purposes listed here above or where we believe such disclosure is required by law or to pursue or defend any claim, Scalable Global Solutions JSC. may make Personal Information available to Scalable Global Solutions JSC. offices, to Scalable Global Solutions JSC.’ clients, as well as to third-party data processors and services providers, existing investors, assignees, acquirers, regulatory and/or administrative authorities, courts, police authorities, arbitrators, experts, adverse parties and/or its advisers worldwide, each of whom may be located in countries that do not adduce the same level of protection of Personal Information as in an individual’s country of residence, and in particular as in the European Union. [Those persons may also need to disclose or transfer the Personal Information received from Scalable Global Solutions JSC. to third parties worldwide, again for the purpose mentioned above.] In any case, Scalable Global Solutions JSC. will provide its best efforts to ensure that data so transferred or disclosed will remain subject to a security and confidentiality regime comparable to the standards set forth here.

Any individual who might object to his or her Personal Information being made accessible to all of Scalable Global Solutions JSC. offices worldwide, who wants to be considered for positions only within a specific geographical area, or who wants to object to the transfer of his or her data outside a specific geographical area (and notably the European Economic Area) should inform us of this concern.  If this should be the case, we will restrict or terminate accordingly the processing of that individual’s Personal Information.

 

Security

Scalable Global Solutions JSC. takes and requires that its service providers and third-party processors also take appropriate technical and organizational measures to protect Personal Information against accidental or unlawful destruction or accidental loss or alteration, misuse, unauthorized access, disclosure, and against all other unlawful forms of processing as defined by the applicable law of Personal Information under our control (e.g., multiple levels of user authentication, industry standard security).

 

Retention

We may maintain Personal Information, including as part of the database described above, for such period of time as may be appropriate in connection with the purposes described in this policy, or for legal or regulatory reasons.

 

Data Subjects’ Requests

In accordance with applicable state or national data privacy legislation, an individual may have the right to contact Scalable Global Solutions JSC. to inquire as to the Personal Information we may have on him or her and to request a copy thereof. Any individual with a record in our database can also request that we rectify his or her Personal Information, or remove his or her record from our database and other systems. He or she may also object, at no cost and at any time, against any further use of his or her data for direct marketing purposes.  When asked to remove a record from our database, we will retain minimal Personal Information for the purposes of preventing future contact, of keeping record of the information disclosed to our clients or other legitimate business purposes, and of complying with any legal obligation.

All such requests will be acknowledged and dealt with as quickly as possible in accordance with applicable law.  Individuals will need to provide appropriate confirmation of identity before a request is processed.

An individual may direct any such requests or any questions relating to data privacy to the Data Privacy Officer at the Scalable Global Solutions JSC. office in his or her country of residence. Alternatively, an individual can send an email to: [email protected]

(ANY CV/RESUME SENT TO THIS ADDRESS WILL NOT BE PROCESSED AND WILL BE DISCARDED.)

To the extent admissible under the applicable law, individuals who submit their résumé to Scalable Global Solutions JSC. will be deemed to have consented to the processing of their Personal Information as set forth in this Privacy Policy, including the transfer abroad of their Personal Information.

 

Updating This Policy

Nothing contained in this Privacy Policy is intended to create a contract or agreement between Scalable Global Solutions JSC. and any individual submitting Personal Information or visiting the Scalable Global Solutions JSC. Web site. We may update and amend this Privacy Policy at any time without prior notification.  Updates or amendments to this Privacy Policy will be published on this Web site.

 

Consent

In any case where an individual would not give or would withdraw his or her consent in relation to the processing or transfer of his or her Personal Information as contemplated in this Privacy Policy, this should in no way be interpreted to restrict Scalable Global Solutions JSC.’ ability to disclose, use and otherwise process Personal Information as allowed by any applicable law and regulation. Scalable Global Solutions JSC. also reserves the right to use, disclose and otherwise process Personal Information to comply with any applicable law and regulations.