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Privacy Policy

We take your privacy very seriously. Please read this Privacy Policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

This Privacy Policy relates exclusively to our use of personal data in respect of an application by you to work with us through the Austin International website. 

For more information on how Austin Fraser may use your personal data please visit https://www.austinfraser.com/legal_documents/privacy_policy.

For more information on how Austin Vita may use your personal data please visit https://www.austinvita.com/en/privacy-policy.

When we collect, use and are responsible for certain personal data about you we are subject to the UK General Data Protection Regulation (UK GDPR) in the UK; the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals and our wider operations in the European Economic Area (EEA); federal and state laws in the United States.

This website is not intended for children under the age of 16 years and we do not knowingly collect data relating to children. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please email privacy@austininternational.com.

 

 

Key terms

It would be helpful to start by explaining some key terms used in this policy:

Privacy Policy

Personal data we collect about you

We collect and use personal data to assess your suitability for a role at one of our Group companies. If you do not provide personal data we ask for, it may delay or prevent us from progressing your application.

We may collect and use the following personal data about you:

  • your name and contact information, including address, email address and telephone number and company details;

  • information to check and verify your identity, e.g. your date of birth, Social Security number, national identifier or other government-issued identification number;

  • citizenship and work authorization status;

  • your personal or professional interests;

  • employment and education history;

  • language proficiencies and other work-related skills;

  • bank account information;

  • your professional online presence, e.g. LinkedIn, Xing, corporate websites, job board websites, online CV libraries, your business card,

  • your contact history, and applications.

We may collect personal information on your visits to this website including your IP address, browser, timestamp, traffic data, location data, weblogs, contact forms and other communication data and the resources that you access. Our collection of this personal information will make your visit to the website easier in the future as we will be able to suggest content that is relevant to you based on the location you access the website from, what content you access and how you interact with it. If you would like further information on this, please contact us at privacy@austininternational.com. 

We may take photos and videos at community led events. These images may be used to share news about and publicise past, current and future events. Images may be used in press releases, printed publicity, social media and published on our website. They will be stored securely, and deleted after they are no longer needed for publicity purposes. If you would prefer not to be photographed or filmed, would like to see your images or would like us to delete them please contact privacy@austininternational.com. 

We may also ask you to complete surveys that we use for research and quality purposes, although you do not have to respond to them.

We avoid processing special categories of data. However, by taking copies of passports or ID it may be that racial or ethnic origin can be revealed. Processing this data is necessary for us to comply with legal obligations.

How your personal data is collected

We collect most of this personal data directly from you – in person, by telephone, text or email and/or via our website. However, we may also collect information:

  • from a third party with your consent, e.g. previous employers;

  • from cookies on our website – for more information on our use of cookies, please see our cookie policy;

  • by reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer;

  • from job boards or social media (e.g. LinkedIn, Xing) where you have submitted your personal data in the knowledge that it may be obtained and processed by recruitment businesses. Where this is the case we will notify you promptly that we have obtained your personal data and allow you the opportunity to ask for this data to be erased or rectified.

Where we collect your information through publicly available sources as set out above, we may do this with the aid of software programs. These programs are given parameters on the requirements of a role and search through publicly available sources to find such candidates. These programs are designed to only output information on candidates that meet the search criteria. The parameters of this program are restricted to only searching for candidate information from public sites where there is a reasonable expectation that such information may be collected and further processed by job recruiters for the purpose of sourcing candidates.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

  • where you have given consent;

  • to comply with our legal and regulatory obligations;

  • for the performance of a contract with you or to take steps at your request before entering into a contract; or

  • for our legitimate interests or those of a third party.

A “legitimate interest” is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

We maintain a database of relevant personal information of prospective and engaged candidates containing historical information as well as current applications.

The table below explains in more detail what we use your personal data for and why.

Privacy 2

Just so you are aware, our online recruitment systems do not use Automated Decision Making tools to assess the suitability of applicants. We utilise the skills and experience of our consultants to assess your capability and experience.

Marketing

We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including events and industry insights.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not always need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly and we will only send you direct marketing emails that promote our company if you have opted in to this.

You have the right to opt out of receiving marketing communications at any time by:

To clarify, contacting you about specific job opportunities is not marketing because we are not advertising or marketing our services.

We may ask you to confirm or update your marketing preferences if you contact us in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside the Group for marketing purposes. We do not host mailings on behalf of third parties.

Who we share your personal data with

We routinely share personal data with:

  • companies within our Group; 

  • other third parties we use to help us run our business, e.g. data storage facilities including in the US and the Cloud; services hosting our Web servers; managing job posting applications via our 3rd party provider Broadbean; analysing data and producing statistics; legal, accounting, audit, finance, insurance and other professional services;

  • individuals and companies who will be providing a reference for you, with your consent.

Where applicable, we will impose appropriate contractual, security, confidentiality and other obligations on 3rd party service providers and processors we have appointed, based on the nature of the services they provide to us. We will only permit them to process your personal data in accordance with the law and our instructions. We do not allow them to use your personal data for their own purposes and when our relationship ends we will ensure your personal data is securely returned or destroyed or anonymised so that you can no longer be identified.

We may also need to:

  • share personal data with external auditors, e.g. in relation to accreditation and the audit of our accounts;

  • disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;

  • share personal data with IT consultants carrying out testing and development work on our IT systems, service providers who we may appoint as data processors and other service providers who may be based in the UK, EEA or United States;

  • share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring – usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Where your personal data is held

The personal data that we control is usually stored and processed in the EEA if you are in Europe or the United States if that is where you are located. However, to deliver our services to you it may be stored on, and processed on, servers situated in the United Kingdom, the EEA, or the United States. We and/or our service providers may also process data in some other countries for customer care, account management and service provisioning (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.

How long your personal data will be kept

We understand our legal duty to retain accurate data and only retain personal information for as long as it is required for carrying out the data processing activities mentioned above. Accordingly, we have a data retention policy and run data cleansing exercises to remove data that we no longer have a legitimate business interest in maintaining.

We will keep in touch with you regularly and will contact you periodically to confirm all the information we hold is accurate and up to date and you still wish for us to hold your data. You can ask us at any stage to remove your information. 

We will keep your personal data while you are an applicant to Austin International and whilst you continue to have an interest in a position with one of our Group. Thereafter, we will keep your personal data for as long as is necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf;

  • to show that we treated you fairly;

  • to keep records required by law.

We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data but it is typically 6 years. We determine the retention period by taking into account:

  • the nature of the personal information;

  • its perceived accuracy;

  • our legal obligations; and

  • whether an interview has taken place.

We may archive part or all of your personal information from our main Customer Relationship Management (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal information on to our database, unless requested to do so. For your information, pseudonymised data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.

Transferring your personal data out of the UK or EEA

As an international companyit is sometimes necessary for us to share your personal data outside the UK/EEA, eg:

  • with our offices or other companies within our Group located outside the UK/EEA;

  • with our service providers located outside the UK/EEA;

  • if you are based outside the UK/EEA.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK or the EEA where:

  • the UK government or, where the EU GDPR applies, the European Commission, has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);

  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or

  • a specific exception applies under data protection law.

These are explained below.

Adequacy decision

If you are in the UK or the EEA, we may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

  • transfers between the UK and the EEA;

  • all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);

  • Gibraltar; and

  • Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

The safeguards will usually include using legally-approved standard data protection contract clauses.

Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, e.g.:

  • you have explicitly consented to the proposed transfer after having been informed of the possible risks;

  • the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;

  • the transfer is necessary for a contract in your interests, between us and another person; or

  • the transfer is necessary to establish, exercise or defend legal claims

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

Third Party Sites

Our site may, from time to time, contain links to other websites not under our control. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

Your rights

You have the following rights, which you can exercise free of charge:

Pirvacy policy

For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of these rights, please:

  • email, call or write to us – see below: ‘How to contact us’; and

  • provide enough information to identify yourself and any additional identity information we may reasonably request from you;

  • let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Although we will do our best to protect your personal information, you should be aware that the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal information transmitted to this website or any third party; for this reason, any transmission is at your own risk. 

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

How to complain

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

If you are in the UK or EEA, you also have the right to lodge a complaint with the Information Commissioner in the UK or any relevant European data protection supervisory authority. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaintor telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was last updated on 26 January 2022. We may change this privacy notice from time to time – for significant changes we will inform you via our website or other means of contact such as email.

How to contact us

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint. Our contact details are shown below:

UK

Austin Fraser International Limited, 33 Soho Square, London, W1D 3QU.

Germany (and the EEA)

Austin Fraser GmbH, Lenbachplatz 1, 80333, München

United States

Austin Fraser, Inc. 500 West 2nd St Suite 1500, Austin, TX 78701