Last updated July 2019
At OC&C Strategy Consultants we take your privacy seriously and we are committed to protecting it.
This policy explains when and why we collect personal information about individuals, how this information is used, with whom we share that information and the rights they have over it. If you apply for a job vacancy with us, details regarding our use of the personal information you provide to us is set out in our separate OC&C Applicants Privacy Notice.
This policy may change from time to time so please check this page occasionally to ensure that you are happy with any changes. This policy was last updated on the date set out at the start of this page. Please see further the section Changes to this policy below.
WHO WE ARE
We are an international consulting firm and operate our business through numerous individual companies (each an "OC&C Company"). For a full list of these companies please see the end of this policy. Whenever providing personal information or interacting with one of our offices, the relevant OC&C Company that corresponds to that office, as set out at the end of this policy, is the ‘controller’ in relation to the processing activities described below. A ‘controller’ is an organisation that decides why and how your personal information is processed and is responsible for such processing.
Where this policy refers to "we", "our" or "us" below, unless it mentions otherwise, it is referring to the particular OC&C Company that is the controller of your personal information.
The version of our site located at www.occstrategy.com that we present to you will depend on the location of the server from which you access it from, as we aim to present the site in the local language of that location. The controller of the personal information you provide to that site or that is collected when you interact with it, is the OC&C Company listed at the end of this policy that corresponds with the relevant version of the site presented to you.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect personal information from you in the following ways:
Personal information you give to us:
This is information about you that you give to us when:
submitting information via our site located at www.occstrategy.com, including local versions and microsites (our "Websites");
following and posting on our social media pages;
corresponding with us by phone, email or in another way,
interacting with us at events;
providing us with your business cards;
we provide services to our client for whom you work;
we receive services from our supplier for whom you work; and
registering for and participating in our alumni network.
This information is provided by you entirely voluntarily and includes personal information you submit on any web forms on our Websites, that you share by posting to our message boards or to the alumni network using our Websites’ community features or that you provide to us in person (e.g. business cards). We may also ask you for information when you report a problem with our Websites. If, at our request, you complete any surveys for research purposes, we will collect your personal information in such circumstances as well. The information you give to us may include your name, address, email address and phone number, enquiry details and other business and contact information, and may include records of any correspondence and responses to any surveys.
If you do not give this information to us, you may be unable to use or interact with certain parts of our Websites, communicate with us effectively, comply with the contractual obligations that the organisation for whom you work is under or allow us to comply with our own obligations if you work for an organisation that is our client.
Personal information we collect about you:
We may automatically collect the following information during your visits to our Websites: traffic data, location data, device data, weblogs and other communication data, and details of the resources you access. We also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Please see our Cookies Policy for further information. We may also collect any personal information which you allow to be shared that is part of your public profile as an alumni or on third party social networks.
Personal information we may receive from other sources:
We obtain certain personal information about you from other sources (including those outside of our business) which may include other OC&C Companies, our suppliers and our clients. The sources that may send to us personal information about you are as follows:
|Source of personal information||The categories of personal information (as described in the section below) that we obtain about you from this source|
|Other OC&C Companies||All categories|
|Our suppliers||Behavioural, Biographical, Contact, Correspondence, Identity, Employment, Fraud|
|Our clients||Behavioural, Contact, Correspondence, Identity|
CATEGORIES OF PERSONAL INFORMATION WE PROCESS ABOUT YOU
We process different types of personal information about you. To make it easier to understand the information that we use about you, we have categorised this information in the table below and provided a short explanation of the type of information each category covers.
|Category of personal information||Description|
|Behavioural||your activities, actions and behaviours|
|Biographical||your life experiences|
|Contact||information which can be used to address, send or otherwise communicate a message to you|
|Identity||information contained in a formal identification document or social security or other unique reference relating to you|
|Monitoring||information relating to the surveillance or monitoring of your activities|
|Employment||your previous, current or future employment details|
|Fraud||information relating to the occurrence, investigation or prevention of fraud|
|Legal||information relating to legal claims made by or against you or the organisation for whom you work or the claims process|
|Correspondence||information contained in our correspondence or other communications with you or your work colleagues|
HOW WE USE YOUR PERSONAL INFORMATION
The purposes for which we use your personal information and the legal basis under data protection laws on which we rely to do this are explained below.
Where you have provided consent
We may use and process your personal information where you have consented for us to do so. If you work for an unincorporated business, are a member of our alumni network or a candidate interested in our recruitment efforts, we will contact you via email or post with marketing information about our services if you (i) register for an account with us online and indicate that you would like to receive such marketing from us; (ii) sign up to insights (by email and/or post) or news (by email) via our Websites or other medium where available; or (iii) when you refresh your marketing preferences and opt-in when responding to a request from us to do so.
You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent for further details.
Where processing is necessary for us to pursue our legitimate interests
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, for the following purposes:
Processing necessary for us to promote our services and our business
- to create a profile of you and analyse this to obtain insight about market or industry trends, client behaviours which inform our marketing strategy, and to enhance and personalise your experience as a visitor (as well as the marketing information we contact you with in the ways described in the paragraph below);
- if you work for a corporate business, to contact you by email or by telephone with marketing information about our products and services. We will use your personal information to tailor or personalise the marketing communications you receive to make them relevant to you;
Processing necessary for us to support our clients and prospects with sales and other enquiries
- to correspond and communicate with you when supporting you in connection with our services or your queries in relation to them;
Processing necessary for us to respond to changing market conditions and our clients' needs
- for market research in order to improve the services that we and other OC&C Companies deliver;
- to notify you about changes to our services and our business;
Processing necessary to manage and administer our alumni network and prospective recruits
- to keep in touch with our alumni, and prospective recruitment candidates through non-promotional mailings, events and surveys;
- to maintain and share marketing and career development contacts within the alumni network and with prospective recruitment candidates;
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
- to administer our Websites and our social media pages and for our internal operations, including troubleshooting, testing and statistical reporting purposes;
- to enable us to make payments to contractors and freelancers who provide services to us;
for the prevention of fraud and other criminal activities;
- to verify the accuracy of information we hold about you and create a better understanding of you as a visitor to our Websites;
- for network and information security purposes in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- for the purposes of a corporate restructure or reorganisation or sale of our business or assets;
- for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we or other OC&C Companies hold about you;
- to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and
- for general administration including managing your queries, complaints, or claims, to send service messages and to provide you with important information about our business.
Where required to comply with our legal obligations
We will use your personal information to comply with our legal obligations:
- to assist any public authority or criminal investigatory body, where we are under a legal obligation to do so;
- to identify you when you contact us;
- to verify the accuracy of data we hold about you; and
- to respond to and resolve your complaints in relation to our services.
OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION
Other OC&C Companies
We may share your information with other OC&C Companies. They may use your personal information in the ways set out in How we use your personal information, in connection with the services they provide, including where they complement our own range of services.
Please see the end of this policy for the details of the OC&C Companies with whom we may share your personal information, including their locations.
Our suppliers, service providers and other recipients
We may share your information with our third party service providers, agents, subcontractors and other organisations (as listed below) for the purposes of providing services to us or directly to you on our behalf.
|Recipient / relationship to us||Industry sector (& sub-sector)|
|Accountancy services||Professional services (accountancy)|
|Banks, payment processors and financial services providers||Financial (banking)|
|Cloud storage providers||IT (cloud services)|
|Digital agencies||Advertising (digital)|
|Financial auditing services||Audit (financial)|
|Government tax administration offices||Government (tax)|
|Data deletion and archiving providers||IT (data lifecycle management)|
|T support service providers||IT (support and maintenance)|
|Legal advisers||Professional services (legal services)|
|On-site security access control services||Security (on-site)|
The recipients mentioned above are located in Europe, USA and China.
When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
When we share your personal information to third parties that are controllers of that information, they may disclose or transfer it to other organisations in accordance with their data protection policies. This does not affect any of your data subject rights as detailed below. In particular, where you ask us to rectify, erase or restrict the processing of your information, we take reasonable steps to pass this request on to any such third parties with whom we have shared your personal information.
Other ways we may share your personal information
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we are under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.
WHERE WE STORE YOUR PERSONAL INFORMATION
All information you provide to us may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen where any of the OC&C Companies are located in a country outside of the EEA or if any of our servers or those of our third party service providers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the UK and so may not protect the use of your personal information to the same standard.
If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include
- ensuring the non-EEA countries to which standards are made have been deemed adequately protective of your personal information for the purposes of data protection law by the relevant bodies;
- mposing contractual obligations on the recipient of your personal information using provisions formally issued by relevant bodies for this purpose. We use these provisions to ensure that your information is protected when transferred to OC&C Companies outside EEA; or
- ensuring that the recipients are subscribed to ‘international frameworks’, such as the EU-US Privacy Shield that aim to ensure adequate protection.
Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.
If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to receive those services.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR
We do not retain personal information in an identifiable format for longer than is necessary.
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We determine the period of retention of your personal information based on the following criteria:
- Retention in case of queries. We will retain your personal information in case of queries from you, including on behalf of an organisation for whom you work;
- Retention in case of claims. We will retain certain of your personal information for the period in which you or a third party might bring claims against us;
- Retention in accordance with legal and regulatory requirements. We will carefully consider whether we need to retain your personal information after the period described above in case of a legal or regulatory requirement
The exceptions to the above are where:
- you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Erasing your personal information or restricting its processing);
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing below);
- we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
- in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
SECURITY AND LINKS TO OTHER SITES
We implement appropriate technical and organisational measures to keep your personal information safe and secure.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our Websites and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Our Websites may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our Websites from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
AUTOMATED DECISION MAKING
We do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this policy and inform you if this position changes.
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either the date that we have confirmed your identity or, where we do not need to do this because we already have this information, from the date we received your request.
- Accessing your personal information
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
- Correcting and updating your personal information
The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.
In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.
- Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
- Objecting to our use of your personal information
Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under How we use your personal information, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data. You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool included in all our marketing communications.
- Erasing your personal information or restricting its processing
In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request. You may also ask us to restrict processing your personal information where you believe it is unlawful for us to continue processing, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
- Transferring your personal information in a structured data file ('data portability’)
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under How we use your personal information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
CHANGES TO THIS POLICY
We may review this policy from time to time and any changes will be notified to you by email, where possible, or otherwise by posting an updated version of this policy to our Websites. Any changes will take effect 7 days after the date of our email or date of posting (as applicable), unless we state otherwise. We recommend you regularly check for changes and review all updates to this policy.
Please direct any queries about this policy or about the way we process your personal information to our Chief Operating Officer using our contact details below.
If you wish to write to us, please write to OC&C Strategy Consultants, 6 New Street Square, London, EC4A 3AT or the applicable office address for the relevant OC&C Company listed at the end of this policy.
Our email address for data protection queries is firstname.lastname@example.org, alternatively you can use our Contact Us form online.
If you would prefer to speak to us by phone, please call +44 20 70 10 8000.
|OC&C Company Name||Country||Registered Address||Registration Number||Office Address|
|OC&C Strategy Consultants LLP||UK||6 New Street Square, London EC4A 3AT||OC323409||6 New Street Square, London EC4A 3AT|
|OC&C Services Ltd||UK||6 New Street Square, London EC4A 3AT||02980806||6 New Street Square, London EC4A 3AT|
|OC&C France SAS||France||4 Place de l’Opéra 75002 Paris||831 537 147||RCS Paris 4 Place de l’Opéra 75002 Paris|
|OC&C Strategy and Analytics GmbH||Germany||Ludwigstraße 9, 80539 München, Deutschland||HRB 236 847||Ludwigstraße 9, 80539 München, Deutschland|
|OC&C Strategy Consultants sp z.o.o||Poland||Piękna 18, 00-549 Warsaw||123 120 21 35||Piękna 18, 00-549 Warsaw|
|OC&C Strategy Consultants sp z.o.o sp. kom||Poland||Piękna 18, 00-549 Warsaw||525 261 54 59||Piękna 18, 00-549 Warsaw|
|OCC DANISMANLIK A.S.||Turkey||Esentepe Mah. Büyükdere Cad. No:127 Astoria Alışveriş Merkezi A Kule K:5 No:13-15 Şişli-İstanbul, Turkey||460053||Esentepe Mah. Büyükdere Cad. No:127 Astoria Alışveriş Merkezi A Kule K:5 No:13-15 Şişli-İstanbul, Turkey|
|OC&C Strategy Consultants USA Inc.||USA||545 Madison Ave, New York, NY 10022, USA||EIN 47.525 2441||545 Madison Ave, New York, NY 10022, USA|
|OC&C Strategy Consultants||China||Unit 4, Block 3, No. 402 Zunyi Road, Changning District, Shanghai, China||91310000MA1FW1MK30||1909-1911, 19F, Shui On Plaza, 333 Middle Huai Hai Road,Huangpu District Shanghai, China 200021|
|OC&C Holdings Limited||Hong Kong||1806, 18th Floor, Tower Two, Lippo Centre, 89 Queenswa||2268959||2603 Golden Centre, 188 Des Voeux Road Central, Hong Kong|
|OC&C Holdco Italy S.r.l||Italy||Via Borgonuovo 14/16
|10978950962||Via Borgonuovo 14/16