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Customer Satisfaction Data Protection Notice (English)

Introduction to the Data Protection Notice

Please read this Data Protection Notice (“Notice”) to continue. It sets out how and why your Employer and SHL collect your personal information. For any defined terms which are not defined on this page, please see the definitions included within the Notice.

Please read the entire Notice carefully.

If you have questions about this Notice, please email dataquestions@shl.com.


Data Protection Notice

This Notice was last updated 7 February 2020.

1. Who we are

This Notice describes how SHL Group Limited of The Pavilion, 1 Atwell Place, Thames Ditton, Surrey KT7 0NE, England (together, SHL or we or us) use your information collected through this online survey.

SHL will process and collect information about you when you complete an SHL Customer Satisfaction Survey (“Survey”) in accordance with this Notice. Some information is personal information (“Personal Information”) about you or from which we can identify you.

This Notice also covers us, and our affiliated group of companies, where we are data controller. Each group company is a data controller and we’ve listed them here.

Section 2 sets out the way SHL use your information: what is collected, how it is collected, how it is used, why it is used, who it is shared with and the rights to which you will be entitled.

Section 3 provides additional information on who we share your data with and an overview of your rights under data protection law.

2. SHL as the Data Controller

When you complete a survey we use the Personal Information about you that you have provided us in the course of receiving services from us and we use this Personal Information for the purposes outlined below. We will be data controller in respect of this information and we will be responsible for your Personal Information including for what purposes your information is collected and used.

If you have any questions on the processing of your data by SHL as data controller you can contact the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice.

What we collect

We collect and process the categories of data as set out below. The categories of data which are collected about you vary depending on the type of Survey. Not all the categories of data listed below may be collected about you. If you have any questions on the processing of your data by SHL as data controller you can contact the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice.

What we collect

Information that you give us when you requested services from us needed to offer you the opportunity to complete a Survey, including:

i. “Participant Data” which includes your:

  • Name;
  • email address;
  • country of residence

ii. “Survey Data” which are your answers to the survey questions.

This includes asking for some information about some business outcomes identified as important to the service we provided you, such as:

  • Customer experience – resolution, speed of answer, agent knowledge and impression of SHL
  • Effortless Experience (CES) – how easy it was for SHL to handle your request
  • Net Promoter Score (NPS) – understanding the loyalty of our customer relationships
  • Continuous Improvement – understanding what improvements will drive efficiency and resolve your issues quicker, with greater accuracy; and to strive to be leading edge in the market

Using your Survey Data we generate an aggregated summary of the survey responses from you and other respondents where individual responses cannot be identified (“Survey Report”).

How we use this data

We use your Participant Data to invite you to complete a Survey. Then we anonymise a combination of your Participant Data, Survey Data to:

  1. Combine your Survey Data with the responses of others to compile an anonymised summary Survey Report;
  2. Improve, adjust, manage and administer our services

Why we use it

SHL uses the aggregated Survey Report because we have a legitimate interest to improve our services.

If you require further information regarding our legitimate interests as applied to your personal data, please contact the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice.

We will also process your Personal Information if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claim against us.

How long we keep it

We keep your Survey Data for our own purposes in a de-identified form for a maximum of seven years.  We will not delete your Personal Information if it is relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

We keep your Country of Residence for seven years.

Where your Personal Information will be held

We store your Personal Information in data centres located in Germany and backed up in Ireland. SHL affiliates also transfer your Personal Information within the EEA (Europe Economic Area).

Additionally, your Personal Information is transferred to the United States, India, South Africa and United Kingdom (“SHL Non EEA Processing Locations”) where a limited number of personnel in our SHL Non EEA Processing Locations, as well as our trusted third-party vendors and service providers, have access to Personal Information in order to provide services. As the SHL Non EEA Processing Locations are in countries which do not have equivalent data protection laws to those applicable in the EEA we have an Intragroup Agreement in place, signed by all SHL affiliates, which contains the European Union (EU) Standard Contractual Clauses (SCCs) which have been approved by the EU data protection authorities for the transfer of data outside the EEA. Our third-party vendors and service providers are also required to sign up to SCCs in accordance with Article 46 of the General Data Protection Regulation. All SHL affiliates have the same technical, physical, and administrative security controls and are required to comply with our data protection policies and procedures, applicable laws, governing the collection and use of personal information.

We are happy to provide you with copies of the regulator-approved SCCs, which you can request from the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice.

When do we share Personal Information

We have set out the circumstances in which we will share your data with third parties below:

  • We will share the Survey Report within our group companies when required to provide maintenance and support services and so that we can continue to improve the services we provide across the group.
  • We will also share your information with our trusted third-party service providers, including Qualtrics, our survey tool provider, our IT security providers and our cloud hosting platform providers. Our service providers will be required to meet our standards on processing information and security.

3. Data Sharing and Data Subject Rights

Data Sharing

The Employer and SHL as data controller will share your data with the following third parties in the below circumstances:

  • If we are discussing selling or transferring part or all of our business, Personal Information will be transferred to prospective purchasers under suitable terms as to confidentiality;
  • If we are reorganised or sold, Personal Information will be transferred to a buyer who can continue to provide services to you;
  • If we are required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police;
  • If we are defending a legal claim your Personal Information will be transferred as required in connection with defending such claim.

Data Subject Rights

We’ve listed the rights you have over your Personal Information and how you can use them below. These rights are subject to exemptions in applicable law and will only apply to certain types of information or processing.  For the Personal Information where we are data controller, you can exercise these rights by contacting the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice.

  1. The right to withdraw consent: Where we have obtained consent for some of the ways we use your information you can remove that consent at any time by contacting the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice.
  2. You can ask us to confirm if we are processing your Personal Information and, if we are, you can ask for access to that Personal Information as well as further details including why your data is being used and for what purposes.
  3. You can ask to correct your Personal Information held by us if it is wrong.
  4. You can ask us to delete your Personal Information.
  5. You can ask us to restrict how we use your Personal Information.
  6. You can ask us to help you move certain Personal Information to other companies. To help with that you have a right to ask that we or the Employer provide your Personal Information in a machine-readable format to another company.
  7. You can ask us to stop using your Personal Information, but only in certain cases. This applies where we are processing your personal information based on a legitimate interest (or those of a third party) and you can object to processing on this ground. However, we will be entitled to continue processing your information based on our compelling legitimate interests.

You also have a right to make a complaint to a Supervisory Authority. Where we are the data controller you can contact the UK Information Commissioner’s Office; or the local data protection regulator in your jurisdiction.

Questions or Complaints

If you have any questions about this Notice please contact the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice.

Changes to the Notice

This Notice will be changed from time to time. If we change anything important about this Notice (the information we collect, how we use it or why) we will provide a prominent link to it for a reasonable length of time following the change.

If you would like to access previous versions of this Notice, please contact the SHL Data Protection Officer (DPO) on dpo@shl.com or the contact details included at the end of this Notice.

Other policies

Security

We are committed to keeping your personal information safe. We have implemented physical, technical and administrative measures to help prevent unauthorised access or use of your information. For more information about the security measures we have please see our: Security Policy.

Sanctions

SHL products and services are subject to US sanctions law. As a result, prohibited individuals, or those located in certain countries (Cuba, Iran, North Korea, Sudan and Syria), are not authorised to take Surveys on our systems. Please contact us at dataquestions@shl.com with any questions.

SHL Data Protection Officer Contact Details:

Email: dpo@shl.com

Postal Address: Data Protection Officer, SHL Group Ltd, The Pavilion, 1 Atwell Place, Thames Ditton, Surrey, KT7 0NE, England.