The term personal information as used throughout this policy, applies to any data relating to an identified or identifiable individual, including data that directly or indirectly identifies an individual.
Spencer Ogden is the data controller for the processing of personal information under applicable data protection law.
Personal information collection
Spencer Ogden will collect and use the following kinds of personal information:
- Information you provide to Spencer Ogden, such as information that you provide using for the purpose of registering with the website, information that you provide for the purpose of subscribing to the website services and any other information that you send to Spencer Ogden;
- Information that is automatically collected, such as information about your use of this website.
- Spencer Ogden may also collect personal information from other websites that display information about you publicly, such as: social media accounts like Facebook and Twitter, your online profile on your current employer’s network, articles about you or other public listings of your profile.
Spencer Ogden’s use of personal information
Spencer Ogden will use the personal information it collects to perform activities associated with providing the website and website services such as:
- Enabling your access to and use of the website and the website services;
- Using Spencer Ogden’s recruitment database to match suitable candidates with roles posted by Spencer Ogden clients;
- Progressing candidates’ applications and administering their personal records;
- Recording details of unsuccessful applicants to be considered for further suitable opportunities that may arise in the near future;
- Communicating with you;
- Administering the website;
- Customizing and personalizing the website for you through the delivery of tailored content and communications;
- Improving the quality of the website;
- Resolving disputes and/or troubleshooting problems; and with your separate consent, sending you marketing communications.
- Identify and authenticate you so you may use the website;
- Necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement);
- Necessary for Spencer Ogden’s legitimate interests (for example, to manage its relationship with you and to improve the website and Spencer Ogden’s website services);
- Based on your consent (for example, to communicate about Spencer Ogden’s services and provide you with marketing information), which may subsequently be withdrawn at any time without affecting the lawfulness of processing based on consent before its withdrawal.
You are required, as a necessity to enter into a contract, to provide Spencer Ogden with personal information for processing as described above. If you do not provide personal information, Spencer Ogden will not be able to provide you with all of the features available through the website and website services.
Sharing personal information about you
Spencer Ogden will share with its clients personal information relating to candidates. Limited members of the Recruitment, Compliance and Customer Services, Finance, HR, IT and Legal teams in Spencer Ogden may access and otherwise process personal information in connection with their job responsibilities or contractual obligations. Your personal information may also be shared with Spencer Ogden affiliate companies and with third party providers who perform services for Spencer Ogden.
Cross-border data transfers
Personal information may be stored and processed by and transferred between Spencer Ogden affiliate companies - and third-party service providers - located in the United States of America and other countries outside of the European Economic Area, including in countries that may not provide the same level of data protection as your home country. Spencer Ogden takes appropriate steps to ensure that recipients of your personal information are bound to duties of confidentiality and Spencer Ogden implements measures such as standard data protection contractual clauses to ensure that any transferred personal information remains protected and secure. A copy of these documents can be obtained by sending an email to firstname.lastname@example.org
Securing your personal information Spencer Ogden has appropriate technical and organisational measures in place to prevent accidental or unlawful access to or destruction, loss, misuse or alteration of your personal information. Spencer Ogden will store all the personal information you provide on secure servers.
Automated decision making
Spencer Ogden does not use automated decision-making technologies
Retention of personal information
Spencer Ogden will retain personal information only for so long as reasonably necessary for the purposes set out above, considering criteria such as applicable rules on statute of limitations and at least the duration of your use of the Spencer Ogden website and services.
You may be entitled, in accordance with applicable law, to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure and portability of your own personal information. Requests should be submitted by using the contact details set out below.
If you are aware of changes or inaccuracies in your personal information, you should inform Spencer Ogden of such changes so that its records may be updated or corrected. You may lodge a complaint with a supervisory authority if you consider that Spencer Ogden’s processing of your personal information infringes applicable law.
This website contains links to other websites. Spencer Ogden is not responsible for the privacy policies or practices of any third party.
Contact Spencer Ogden
Updating this policy
This policy was last updated on 24th May 2018.