Last Updated: October 18, 2022
1. WHAT DOES THIS NOTICE COVER?
This notice describes how Insight Global Ltd (“Insight Global UK“, “we“, ” us” or “our“) processes your personal data online and offline, including where you engage with our website or contact us, if you apply for an internal roles at Insight Global UK, if you supply or partner with Insight Global or if you are an employee or contact at a customer or prospect of Insight Global UK. It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your choices and rights” section.
This notice does not apply to candidates who apply for, or employees or contractors hired to fulfil, roles for Insight Global UK’s clients. Processing of these individual’s data is described in our UK Candidate Privacy Notice. The data processing described in this notice may be limited as required by applicable law.
We also may provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information.
2. WHAT CATEGORIES OF PERSONAL DATA WE COLLECT:
We collect and process personal data about you when you interact with us and our websites, when you obtain services from us, where you visit our offices, when we carry out market research and when your employer engages with us as a customer or supplier. This will typically be provided directly by you. Depending on your engagement with us, it will include:
- Personal information: your name and contact information, such as postal address, email address and phone number;
- Application related information: information related to your application for an internal role with Insight Global UK, including your curriculum vitae (CV), cover letter, employment history, education history, qualifications and skills, reference contact information, position preferences, willingness to relocate, desired salary, interests and aspirations, your interest in hearing about other roles, your special category data if we need to make reasonable adjustments and background screening information if relevant;
- Employment and business information: your position and employer, your work contact details and your interaction with us in your role, including information provided in the course of the contractual or client relationship between you or your organisation and Insight Global UK, or otherwise voluntarily provided by you or your organisation;
- Technical data including information collected during your visits to our website(s), the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating system and platform.
We collect most of this information from you directly. For example, data is collected through communications you send, or your engagement with Insight Global UK. We may generate or collect information about you ourselves. In an online context, much of this is set out in our cookies information below.
Sometimes, we receive information about you from third parties. For example, if you use a “like” or a “share” button for a feature on our sites or apps, then the third party will share information with us. If you participate in activities on third party sites or apps – such as participating in a Facebook application – you may allow us to have access to personal data held by Facebook, or other site or app owners. Where you are engaged by an Insight Global UK supplier or customer, we may receive information about you from your employer. We might also supplement information with data from publicly available sources, or from information on third party business sites such as LinkedIn. If you apply for a role with Insight Global UK, we night receive information from other people (e.g. recruiters, referrals), your referees or third-party job websites (e.g. from LinkedIn if you choose to connect to us with your LinkedIn profile). Where applicable, we also collect data from our third-party background screening provider during the pre-employment screening process, or confirm details directly with educational or professional licensing and certification organisations where confirming your qualifications.
Insight Global UK collects, uses and stores your personal data for the following purposes, which in each case are justified by the legal basis set out in bold:
- Where necessary to enable Insight Global UK’s business to function and pursue our legitimate interests, where these interests are not overridden by your data protection rights, in particular:
- to provide products and services you have requested and to investigate and respond to any comments or complaints you may send us;
- to process your application, to make to make informed decisions on recruitment and assess your suitability for an Insight Global role, communicating with you about your application, responding to your inquiries and scheduling interviews.
- to monitor use of our websites, platforms and services, and use your information to help us analyse, monitor, improve and protect our websites, communications, content and services, both offline and online, including profiling and personalising our services to our customers.
- to protect the security of our premises, assets, systems, and intellectual property and enforce company policies , including protecting ourselves from fraud and verifying the individuals with which we interact as appropriate.
- for general business operations, including in connection with legal claims, compliance, regulatory, audit and investigative purposes (including disclosure of such information in connection with legal process or litigation, or to law enforcement bodies or to employers where appropriate).
- for market research or inviting you to participate in market research
- for marketing purposes, where we are entitled to send you direct marketing without your consent.
- Where necessary to comply with applicable laws: we process data where necessary to comply with laws. Sometimes it is also necessary for us to comply with the orders or instructions of the UK court and tribunals, the UK government and government bodies, regulatory bodies and other legal or regulatory processes or law enforcement bodies. .
- Where you have given your consent: in circumstances where we seek your consent, such as to place non-essential cookies or to carry out direct marketing where we are required to obtain your consent. We will explain the purpose of our processing in any request for consent. Such processing shall be truly voluntary, and you shall be able to withdraw this consent at any time.
When you visit one of our websites, we may also collect, process and use information about you and your use of the website, including any forums you visit and how you arrived at our site. Such information may be collected through “traffic data” and may entail the use of “cookies” or other tracking technologies, IP addresses or other numeric codes used to identify your computer.
4. HOW WE SHARE YOUR PERSONAL DATA
Other Insight Global Entities
We share your personal data with other Insight Global entities, located in the United States, where this is necessary for the purposes set out above. This includes where you interact with employees of Insight Global’s other entities and where this is necessary for Insight Global US to administer and manage group functions (including to make central systems available to our staff) or manage the operation of the UK business.
Government or law enforcement bodies
Personal data may be shared with government authorities and/or law enforcement officials as required for the purposes described above.
Clients and suppliers
Depending on your role, we may share information with a client or a supplier with which you are engaged.
Third party service providers
Personal data will also be shared with Insight Global UK’s third-party service providers (who will process it on our behalf). These third parties include IT service providers, website hosting providers, marketing suppliers, security services, maintenance, call centre operations and identity checking services. Some of our suppliers may be separate data controllers, such as market research organisations, lawyers and accountants. Where appropriate, they may provide you with their own privacy notice.
Sale of our business
In the event that Insight Global UK’s business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners of the business as required for the purposes set out above.
5. WHERE WE TRANSFER YOUR PERSONAL DATA
As a US headquartered company, a number of our IT systems are hosted in the United States and most of our executive team is located there. Relevant information is shared with our affiliated Insight Global companies as described in this notice.
We may transfer your data to some third parties which host or access personal data outside of the UK and EEA. In the event such an organisation is in a country which is not subject to an adequacy decision by the UK government or otherwise considered adequate as determined by applicable data protection laws, we take steps to ensure your personal data is adequately protected, including by adopting standard contractual clauses, unless we can rely on a relevant exemption.
A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.
6. YOUR CHOICES AND RIGHTS
You have the right to ask Insight Global UK for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine-readable format . In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Insight Global UK processing your data, this will not affect any processing which has already taken place at that time.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain complain to a data protection authority. In the UK, this will be the Information Commissioner’s Office.
Where we collect personal data to administer our contract with you or to comply with our legal obligations, this is mandatory and we will not be able to manage the employment relationship without this information. In all other cases, provision of the requested personal data is optional, but this may affect your ability to participate in certain programs or systems, where the information is needed for those purposes. For example, you may not be able to participate in additional offered benefits or programs, or a team activity, if you choose not to provide the relevant information.
7. HOW LONG WE RETAIN YOUR PERSONAL DATA
Insight Global UK will retain and process personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for Insight Global UK to assert or defend against legal claims, until the end of the relevant limitation period or until the claims in question have been settled.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
We use the following criteria to determine retention periods:
- how long the data is needed to provide our services and operate our business;
- whether there are contractual or legal obligations that exist that require us to retain the data for period of time;
- whether any law, statute, or regulation allows for a specific retention period;
- whether an individual has agreed to a longer retention period;
- whether the data is considered to be sensitive data, and
- what the expectation for retention was at the time the data was provided to us.
8. UPDATES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new updated privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.
9. CONTACT US
The data controller for your personal data will be Insight Global UK.
If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact us at [email protected]