Occam Global takes the privacy and security of our clients’ and candidates’ (“Clients”) information seriously. This Policy describes how Occam Global and any affiliates (collectively referred to as “Occam,” “we,” or “us”) collect, use, transfer, and disclose your information. This Policy covers information Occam collects in connection with our Executive Recruitment Services, Human Venture Capital Services, Board Construction Services, and other Consulting Services (collectively, “Services”). This Policy also covers information collected through:
- websites we operate from which you are accessing this Policy (the “Site”),
- our social media pages and apps to which the Site links (collectively, our “Social Media Pages”), and
- HTML-formatted email messages we send to you that link to this Policy (collectively, including the Site and our Social Media Pages, the “Online Systems”).
This Policy also covers other means by which we collect information, for example, in-person discussions, telephone conversations, and other non-electronic communications (i.e., collection through other means than our Online Systems).
What personal information do we collect?
Occam collects information (“Personal Information”) that identifies you as an individual or relates to an identifiable individual in the course of providing Services to Clients. The type of Personal Information we collect about you depends on the situation.
If you are a Candidate, you may provide personal information to us, for example, when you provide us with your resume, talk to Occam associates, or communicate with us in any way in connection with the Services. Further, as described below, we may obtain information about you from other sources. You are not obligated to provide Occam with any information or participate in any of the Services we offer. As such, we will consider any information we collect directly from you as having been provided voluntarily. If, however, you are unwilling to provide us with certain requested information, please understand that this may limit our ability to consider you in connection with the Services.
The information we may collect for all Candidates typically includes:
- Contact details: such as your name, email address, postal address, and telephone number.
- Resume information: such as your contact details, employment history, educational history, professional qualifications, as well as languages and other skills and activities.
- Identification data: such as your civil/marital status, photograph, date of birth, gender, national origin, corporate identifier, national identifier (i.e., social security number or equivalent in your country, driver’s license, or national ID/passport number).
- Lifestyle preferences and personality profile: such as community involvement and memberships, hobbies, social activities, and/or individual preferences, intellectual capacity, personality, behavior, executive competencies, and/or character traits.
- Health, diversity, and criminal conviction information: where appropriate, and in accordance with local law, we may also collect information related to your health, diversity information (including racial or ethnic origin, religious or other similar beliefs, and physical and/or mental health, including disability-related information), and/or details of any criminal convictions.
- Financial information: to reimburse expenses incurred in connection with the Services (e.g., travel, lodging and/or meal costs when attending an interview with a Client), we may collect certain financial information needed to document the expense and to reimburse you (e.g., bank account number and/or credit card number).
- Other information: such as your prior military service, compensation and benefit details (where permitted by local law), performance history, details of any dependents, immigration status, and any other relevant information you may choose to share with us. We also keep a record of your marketing preferences and our contact history with you.
We may also collect any of the above personal information about you from publicly available sources and third parties, including, under the following circumstances: (i) Sources and Referees may disclose personal information about you; (ii) our Clients may share personal information about you; (iii) we may obtain information about you from publicly available third party sources (e.g., LinkedIn, news reports, press releases); and (iv) we may source personal information about you from our third party data providers and degree verification/background check providers. When we obtain information about you from third party providers or vendors, we take appropriate steps to ensure that such third parties are legally permitted or required to disclose such information to us.
Our Clients may provide us with personal information about certain Candidates in connection with our Services (for example, they may provide us with a list of Candidates they would like us to assess through the Services). We typically process this personal information as a processor on our Client’s behalf. We use that information to provide the Services to our Client and as instructed by our Client. Under these circumstances, it is our Client, as the controller, that controls what personal information about you we collect and how we use it. If you have privacy-related questions or concerns about a Client’s privacy practices or the choices a Client has made to share your information with us or any other third party, you should reach out to the Client or review their privacy policies. We are not responsible for the privacy or security practices of our Clients, which may differ from those set forth in this Policy.
We need to collect and use information about you or individuals at your organization in the course of providing the Services to you. We generally only need to have your contact details or the details of individual contact(s) at your organization (such as name, telephone number, email address, and job title) to ensure that our relationship runs smoothly. We also hold information relating to your online engagement with Candidate profiles through our Client applications and will keep a record of our contact with you. We may also hold extra information about you that someone in your organization has chosen to tell us.
Where appropriate and in accordance with local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including: (i) from third party market research and by analyzing online and offline media (which we may do ourselves or employ other organizations to do for us); (ii) from attendee lists at relevant events; and/or (iii) from other limited sources and third parties.
Referee data:
In securing a reference from you about one of our Candidates, we may process your contact details (such as name, email address, and telephone number). We may also process certain professional details (such as your job title, occupation, academic and professional qualifications, and employment history) and your connection to the Candidate (such your relationships to, experience with, and opinions about the relevant Candidate). We generally ask the Candidates to provide us with much of this information but we may supplement it with information we collect about you from publicly available sources (such as LinkedIn) or by asking you directly.
How do we use your Personal Information?
We may use the personal information we collect through our Services in a number of ways.
Candidate data:
We typically use Candidate data for the following purposes: to provide our Clients with Services, including assessing your suitability for executive roles with a Client; contacting you about board and executive search or assessment assignments conducted for Clients; sending your information to our Clients; and/or verifying the details you have provided (such as through psychometric evaluations or by requesting information from third parties (e.g., Referees or degree verification vendors)). We may also use your personal information for other business purposes, such as data analysis and/or to enhance, customize, and improve our Services.
Marketing activities:
To send you information (such as reports, promotions, research, white papers, events and general information about, for example, relevant industry sectors) that we think you may find interesting (in each case, in accordance with your marketing preferences).
Equal Opportunity monitoring:
To ensure that our recruitment processes are aligned with our commitment to ensuring equal opportunities. Some of the data we may collect about you (in appropriate circumstances and in accordance with applicable local law) falls under the umbrella of “diversity information.” This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. Some of this information is considered “sensitive” personal information and, as such, slightly stricter data protection will apply. Where required by law, we will obtain your explicit consent before we use it. Where appropriate and in accordance with local laws and requirements, we will use this information to provide our Clients with diverse pools of qualified Candidates. We may also disclose this data (suitably anonymized where appropriate) to Clients where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes or legal requirements – but again, only where in accordance with applicable local law.
We may also collect other sensitive personal information about you, such as health-related information, religious affiliation, or details of any criminal convictions if this is appropriate in accordance with local law and is required for a role for which we are recruiting you. We will never do this without your explicit consent.
Client data:
We typically use Client data to provide Services to your organization; to manage our relationship and account with you and your organization; and/or for our other business purposes such as data analysis and/or to enhance, customize, and improve our features, products, and services. We may also use Client data to send you information (such as reports, promotions, research, white papers, and event invitations) that we think you may find interesting (in each case, where this is in accordance with your marketing preferences).
Data collected via our website
This section applies to Personal Information that we collect and process through our Site in the usual course of business.
Certain parts of our Site may ask you to provide personal information voluntarily, for example, we may ask you to provide your contact details (like your name, email address, and phone number) to complete surveys, subscribe to marketing communications (like newsletters), submit inquiries, and/or otherwise communicate or interact with us. We may also collect personal information from you offline, such as when you attend one of our events. You are not obligated to provide Occam with any information or participate in any of the Services we offer. As such, we will consider any information we collect directly from you as having been provided voluntarily. If, however, you are unwilling to provide us with certain requested information, please understand that this may limit your ability to participate in the Services.
When you visit our Site, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered Personal Information under applicable data protection laws. Such automatically collected information may include your IP address, device type, unique device identification numbers, browser type, broad geographic location (e.g., country or city-level location) and/or other technical information. We may also collect information about how your device has interacted with our Site, including the pages or content accessed and links clicked. Collecting this information enables us to better understand the visitors who come to our Site, where they come from, and what content is of interest to them. We use this information for internal analytics purposes.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology,” below.
Social media:
Our Site includes social media features, such as widgets that link to a social media website or allow you to share website content. These features may collect your IP address, which page you are visiting, and may set a cookie to enable the feature to function properly. Social media features, such as widgets, are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.
How do we use this Personal Information?
We typically use the Personal Information we collect through our Site in the usual course of our business for the following reasons: (i) to respond to a request that you sent us, such as a request for information about our Services; (ii) to administer, protect, and improve our Site and our Services; (iii) to better understand the preferences of our Site visitors; (iv) to compile aggregated statistics about Site usage; (v) to provide you with marketing and promotional communications (where this is in accordance with your marketing preferences); and/or (vi) for other business purposes such as data analysis or improving our Sites and Services.
Cookies and similar tracking technology:
Like many Sites, we use cookies or other similar technologies to collect and use personal information about you. Please see our Cookies Policy for further information.