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Privacy Overview

1. Introduction

The PA Consulting Group ('PA') is made up of different legal entities, details of which can be found PA Consulting Group trading companies. This privacy notice is issued on behalf of the PA Consulting Group, so when we mention PA, "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the PA Consulting Group responsible for processing your data. PA Consulting Services Limited is the controller and responsible for this website.

PA is firmly committed to privacy, the responsible use of information, the need to safeguard the privacy of our clients and visitors to our website, and to maintaining compliance with privacy legislation. PA will ensure that the data you supply to PA is processed fairly and lawfully, and with skill and care. We take our responsibilities in respect of your personal data extremely seriously.

This statement sets out PA's privacy policy for the collection and processing of personal information through your use of this website, including any information you may provide through this website when you contact us for any reason such as:

joining our marketing list
applying for a role with us
registering for an event
downloading content
requesting information abut our services
sending PA a request for proposal or
filling in a survey.

This website is not intended for children and we do not knowingly collect data relating to children through this website.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

We have a data privacy team who are responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact the data privacy team at privacy@paconsulting.com

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Third-party links

This website may include links to third-party websites, plug-ins and applications as well as embedded content such as YouTube videos. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information which identifies an individual. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Contact Data	includes email address, phone number, postal address or other information included in CVs
Identity Data	includes first name, last name, photo or other information included in CVs
Marketing and Communications Data	includes your Contact Details for us to send marketing communications to you
Profile Data	includes your username and password for PA Job Search and applications made by you
Technical Data	includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data	includes information about how you use our website

We also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How is your personal data collected

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us on this website. This includes personal data you provide when you:
- subscribe to our service, events or publications
- request marketing to be sent to you
- send us information about a request for proposal
- contact us in relation to a business, media, supplier or career enquiry
- apply for a role with PA or
- give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy below for further details.
Third parties or publicly available sources. We may receive personal data about you from analytics providers.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

where we need to perform the contract we are about to enter into or have entered into with you
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
where we need to comply with a legal or regulatory obligation
to match your details with job vacancies at PA, and to engage with you in relation to the recruitment process

Section 5 gives more information about the lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to opt out from marketing at any time by clicking the unsubscribe link in any email you receive from us or by contacting us.

5. Why we use your personal data

In the table below, we have described all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To manage our relationship with you may include: (a) Telling you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To enable you to participate in a competition or complete a survey	(a) Identity (b) Contact (c) Usage (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content, marketing communications and advertisements to you. To contact you following you making a request for further information from us via the website. To measure or understand the effectiveness of the advertising we serve to you. To personalise the PA Job Search site to you when you log in	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy. To provide a personalised PA Job Search site to candidates)
To use data analytics to improve our website, PA Job Search, services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To enable you to apply for jobs at PA, to match you to jobs, to contact you in relation to the recruitment process, and to share your details internally with relevant hiring managers.	(a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical (f) Profile	Necessary for our legitimate interests (to recruit applicants into roles at PA)
To keep your recruitment information on file (if you have asked us to do so) to contact you about future jobs at PA which match your profile and to contact you about PA jobs, services, news and other developments	(a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical (f) Profile	Necessary for our legitimate interests (to recruit applicants into roles at PA)
To conduct online media checks on candidates (as required by regulation in some jurisdictions) to determine if there is any information about you in the public domain that might affect your suitability for the applied role *.	(a) Identity (b) Contact (c) Profile	(a) Necessary for our legitimate interests (to recruit applicants into roles at PA) (b) Necessary in order to comply with a legal obligation (due to the nature of PA's business and the work we undertake for certain clients)

* Note checks will not be undertaken until just before the final stage of the recruitment process. Any information obtained by these checks, which brings your suitability for the applied role into question, will be shared with you so that you will have an opportunity to correct or explain the information before any final decision is made on your application. Information obtained from a check will be not be retained by us should your application not proceed and neither will it be passed to any third party without your consent.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you no longer want to receive marketing communications from us you can click the unsubscribe link in any email you receive from us or contact us.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You will receive marketing communications from us if you:

have requested information from us
purchased services from us
provided us with your contact details when we met you at a PA event, conference or meeting
have a PA Job Search account

and, in each case, you have not opted out of receiving marketing communications from us.

Opting out

You can ask us to stop sending you marketing messages at any time by clicking the unsubscribe link in any email you receive from us or by contacting us.

Where you opt out of receiving these marketing messages, PA may still hold personal data provided to us as a result of a purchase, service experience or other transaction with PA.

Change of purpose

We will only use your personal data for the purposes that we collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Correcting and updating your profile

To help us keep our PA Job Search information up-to-date we would be grateful if you would let us know as soon as any of your contact details change or if you notice any inaccuracies in your details or your PA Job Search profile.

6. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We will not disclose any personal data you have given to us other than as described in this statement, unless you have authorised us to so do, or if we are required to do so by law. Please note that if at any time PA is required by law to release information about you, PA will do so and will co-operate fully with the relevant authorities.

7. International transfers

We share your personal data within the PA Consulting Group. This will involve transferring your data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model Contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them either based on Model Contracts, or if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

9. Data retention

How long will you use my personal data for?

We will only retain your 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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes, however different retention periods may apply to such data in different countries to reflect national legislation.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you

For people who apply for jobs at PA, if your application is successful we will retain relevant personal data in your employee record file in accordance with PA’s GDPR Privacy Notice For Employees, Workers and Contractors. If you are an unsuccessful candidate, we shall retain your personal data for such period as permitted by law. In the UK this will be eighteen months from the date we decide whether to reject an applicant. In the Netherlands, Germany, Denmark, Sweden, and Norway this will be six months from the date we decide whether to reject an applicant. This is to ensure we can comply with contracts we have in place with recruitment agents and for other matters than may arise in connection with your application.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Glossary

Lawful basis

Legitimate Interest means PA's interest in holding and managing your details to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

Internal Third Parties

Other companies in the PA Consulting Group and who are based in the EU, US, Qatar, United Arab Emirates, India and Mexico and provide IT and system administration services and undertake leadership reporting.

External Third Parties

Service providers acting as processors based in the European Union and outside the European Union who provide IT and system administration services.

Professional advisers acting as processors including marketing professionals, lawyers, bankers, auditors and insurers based in the European Union or outside the European Union who provide consultancy, banking, legal, insurance and accounting services.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

12. Cookie policy

What are 'cookies'?

'Cookies' are small text files that are stored by the browser on your computer or mobile phone. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Websites can read from and write to these files, allowing them recognise user preferences or return visitors.

Note that cookies are not software, they are not programs, they cannot carry viruses and they cannot install any kind of malware on the host computer.

The data collected within these cookies are anonymised data based on IP addresses and do not contain any individual information.

Use of cookies on this site

We use four different types of cookies on our site.

You can find below why we use them and detailed information on each of them.

Strictly necessary cookies:

These cookies are part of the technical set up of the website and are necessary for all users. They allow you to browse the website without difficulties.

Cookie Name	Description	More information
ARRAffinity	Websites run on the Windows Azure cloud platform use this cookie for load-balancing. It makes sure the visitor's page requests are routed to the same server in any browsing session. This cookie is strictly necessary for the website's functionality and can't be turned off.
ASP.NET_SessionId	Sites written with Microsoft .NET-based technologies use this cookie to maintain an anonymised user session.Web servers use this cookie to identify users as unique visitors. It maintains continuity as visitors navigate between pages. It also helps identify how may users visit a site.	Learn more about this cookie
__cfduid	Sites using CloudFlare use this cookie to improve security for those accessing the site from a shared IP address (eg if you're using free public Wi-Fi). It holds no information about the user.	https://support.cloudflare.com/hc/en-us/articles/200170156-What-does-the-Cloudflare-cfduid-cookie-do-
__RequestVerificationToken	Web applications built with ASP.NET MVC technologies use this cookie to prevent forgery. It's designed to stop unauthorised posting of content to a website, known as Cross-Site Request Forgery. It holds no information about the user and is destroyed on closing the browser. This cookie is strictly necessary for the website's functionality and cannot be turned off.
JSESSIONID	Preserves users states across page requests.
BIGipServer#	Distributes traffic to websites on several servers in order to optimise response times.

Performance cookies:

These cookies collect information about how visitors use the website so we know how the website performs. We use them to improve how the site works. All information these cookies collect is anonymous.

Cookie Name	Description	More information
_ga	Allows Google Universal Analytics to distinguish unique users and calculate visitor, session and campaign data. It expires after 2 years.	Learn more about Google Analytics privacy Learn how to opt out of being tracked by Google Analytics across all websites
_gat	Allows Google Universal Analytics to limit the collection of data on high traffic sites. It expires after 10 minutes.
_gid	Allows Google Universal Analytics toregister a unique ID that is used to generate statistical data on how the visitor uses the website.
collect	Ssends data to Google Analytics about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels.

Targeting cookies:

These cookies provide us information about our visitors’ digital behaviours. Some of them can be combined with personal data visitors have consented to give to us so we can deliver marketing or advertising communications that are relevant to their interests. They're also used to limit the number of times you see a promotion and help measure the promotion's effectiveness. They can tell organisations, such as LinkedIn, that you've visited our site. Targeting cookies can be linked to site functionality provided by the other organisation.

Cookie Name	Description	More information
trwv.uid	Allows content personalisation. It uses an anonymised alphanumeric code to match users with the Marketo Web Personalisation record.
_mkto_trk	Allows us to link visitor behaviour to the recipient of an email marketing campaign through Marketo. This information is only linked to an individual when they voluntarily submit that data through a form on our site.
_mktomai_trk
trwsa.sid	This cookie helps tailor content through Amobee (owned by LinkedIn). It collects non-personally identifiable information.	https://www.amobee.com/trust/consumer-opt-out/ https://www.amobee.com/trust/privacy-guidelines/
bcookie	Used by the social networking service, LinkedIn, for tracking the use of embedded services.	For more information visit: LinkedIn's privacy policy
BizoID
bscookie
lidc
UserMatchHistory	LinkedIn Ad analytics cookie that comes from LinkedIn insights and ads tags.
ads/ga-audiences	Used by Google Ad Words to re-engage visitors that are likely to convert to customers based on the visitor's online behaviour across web sites.

Functionality Cookies:

These cookies let the website remember your choices to improve your experience when browsing the site. Choices can be your acceptance of the Cookie policy or the browser you have used. This information is usually anonymised and is not used for any other purpose.

Cookie Name	Description	More information
EPiForm_BID	We use this cookie so Episerver can distinguish one browser from any other browsers a visitor is using while surfing the internet.
EPiForm_VisitorIdentifier	We use this cookie so Episerver can identify who's interacting with the website.
EPiForm_{FormGUID}_{VisitorIdentifier}	We use this cookie so Episerver can keep track of which forms a user is interacting with and if they're completed. The structure of the cookie name is a common root, EPiForm_, followed by an anonymous, unique alphanumeric code.
allowCookies	This cookie indicates that you gave your consent to the use of cookies on our site by clicking 'close' on the cookie message. It also stops the message from displaying.
Cemlink	These cookies give access to the CEM map after you've registered via a form on our website.
cemMap
paBenchmarkUrl	This cookie stores your innovation benchmark score so you can revisit the site and review your results without filling in the survey again.

Please contact us if you want more information about the cookies we use.

How to opt-out from cookies in your browser

All modern browsers allow you to change your cookie settings. These settings will typically be found in the 'options' or 'preferences' menu of your browser. To understand these settings, this link may be helpful, otherwise you should use the 'Help' option in your browser for more details.

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