- The data we collect about you
- How is your personal data collected
- How we use your personal data
- Why we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
- Candidate privacy notice
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.
- joining our marketing list
- applying for a role with us
- registering for an event
- downloading content
- requesting information about 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 under the age of 13 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 firstname.lastname@example.org.
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.
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.
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.
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.
- Third parties or publicly available sources. We may receive personal data about you from analytics providers.
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.
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:
(b) Asking you to leave a review or take a survey
(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
(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
|(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
(e) Marketing and Communications
|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
|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
(d) Marketing and Communications
|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
(d) Marketing and Communications
|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
|(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 not be retained by us should your application not proceed, and neither will it be passed to any third party without your consent.
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.
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.
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.
We share your personal data within the PA Consulting Group.
Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by using
- specific contracts with service providers approved by the European Commission or Information Commissioner’s Office which give personal data the same protection it has in Europe or the UK respectively.
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.
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
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:
- Request access to your personal data.
- Request correction of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
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.
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.
Internal Third Parties
Other companies in the PA Consulting Group and who are based in the EU (European Union), The USA, United Arab Emirates, Norway, and New Zealand, 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.
Please contact us if you want more information about the cookies we use.
Candidate privacy notice
This notice sets out how PA Consulting will process your data during and after your application for a role. For the purposes of “Data Protection Legislation” PA Holdings Limited together with the local EU office (“PA”) is the Data Controller of any data collected.
The data we will process; how we use it; our basis for processing
As part of the recruitment process, we need to collect your data and we will process it in accordance with this notice. PA will process your data to assess your skills, qualifications, and suitability for roles (during the period we hold your data), carry out background and reference checks (where applicable), communicate with you about the recruitment process, keep records related to our hiring processes, to produce related management reporting and analysis and to comply with legal or regulatory requirements.
It is in our legitimate interests to use your data for recruitment purposes to bring new talent into PA. If you are successful we will process your personal information to enter into a contract of employment with you. If you do not provide your personal data, we will not be able to progress your application.
In connection with your application, we will collect, store, and use the following categories of personal information about you, including all the information you have provided to us in your curriculum vitae, covering letter, application (including name, title, address, telephone number, personal email address, employment history, qualifications, location) case studies, test(s) / employment screening / security clearance and / or via interviews.
The information you provide will be used to process your application for a role at PA. Specifically, to determine whether you meet the basic requirements for the role, and where applicable to invite you for an interview. If we offer you a role, we will then take up references and carry out background checks (including the criminal record checks described in this notice) before confirming your appointment.
Information collected from third parties
In addition to the information you provide to us, we also collect the following categories of personal data about candidates from the following sources:
- name, address, email, curriculum vitae details, photograph, candidate feedback;
Hire Right: a background check provider and Disclosure and Barring Service (or similar services in jurisdictions other than England and Wales
- criminal convictions, clearance details for security work and related data of a national security nature (see in addition below under Information about criminal convictions); and
Your named referees
- suitability for employment and previous employment details.
Special category data
In order to process your application we will ask you about any access arrangements we may need to make to our recruitment process and as such we may collect some categories of special category data such as disability data. We will only use this special category data to ensure an accessible and inclusive recruitment process, and if your application is successful, to ensure we can meet any ongoing access requirements or reasonable adjustments you may require in the workplace.
PA is an inclusive employer and is keen to ensure that it continues to attract diverse talent. To monitor this, PA will invite you to submit special category data relating to your race or national or ethnic origin, religion, or your sexual life or sexual orientation along with non-special category data about your gender, gender identity, marital status or veteran status (together “Diversity Data”). We will use that data on an anonymised basis to enable PA to analyse the diversity of candidates for internal review, to evaluate progress against our Global Inclusion & Diversity Strategy’s aims, for monitoring and reporting and to determine any changes we want to make to our business (including changes to policies and procedures) and to support a more diverse workforce (“Diversity Purposes”). We may not ask for all categories of data for Diversity Purposes in all countries.
The submission of diversity data is optional, and we will ask for your explicit consent for PA to process this (under Article 6.1(a) and Article 9(2)(a) of the Data Protection Legislation) at the point of collection. This data will not be used to process your application, or accessible by any decision makers in the application process. Providing data for Diversity Purposes will not adversely impact your application if you choose not to do so.
If your application for a role with PA is successful, we would like to move your diversity data into your HR file. This data is only used to monitor and report on PA’s performance against its Inclusion and Diversity objectives and is only accessible by you, and a limited number of nominated HR administrators responsible for processing the data. Your data will be used on an aggregated and anonymised basis to enable PA to monitor our performance against our Global Inclusion & Diversity Strategy aims. You may opt out of this anonymised reporting at any time, including after joining PA, by speaking to HR Shared Services, or by removing the data yourself from your HR file.
Information about criminal convictions
We may process information about criminal convictions as part of the recruitment process. We process criminal record data under Article 6 of EU and UK GDPR. PA has a legitimate interest in ensuring you are suitable for a role with PA and satisfies the vetting requirements imposed on us by certain clients. The data we process and the basis on which we process such data under Article 10 EU and UK GDPR is as follows:
- In the UK, we will undertake vetting in line with the UK Government Baseline Personal Security Standard for all candidates to whom a conditional offer of employment has been made. This includes a “basic” search with the Disclosure and Barring Service, Disclosure Scotland or Access Northern Ireland (as applicable) for “unspent” criminal records check. Additional searches in respect of overseas criminal convictions may be necessary in some cases. In addition, for all candidates [to whom a conditional offer of employment has been made will be subject to Security Clearance or Developed Vetting clearance, pursuant to which we may undertake “standard” checks which will disclose information about both spent and unspent convictions, cautions, both spent and unspent and police reprimands and warnings. We undertake this processing on the basis that it is necessary for our or your rights or obligations in connection with employment (paragraph 1, Schedule 1 DPA 2018) or otherwise on the basis of your consent (paragraph 29, Schedule 1 DPA 2018)
- In the Netherlands, we may require you to submit a certificate of conduct (VOG), which is a certificate that states that you have not committed any criminal offences that are relevant for your role. Applications must be made to Justis. We will not process information about criminal convictions as part of the recruitment process. If Justis intends to refuse the VOG, it will correspond with you and give you the opportunity to give your view on the intended refusal. PA Consulting will not be informed by Justis of the refusal of the VOG, nor will anything be communicated about the reasons therefor. Upon granting the VOG, we need to validate its authenticity and will keep a signed copy of it in our files. You are allowed to keep the original. We undertake this processing on the basis that it is permitted under Policy Rules VOG-NP-RP 2018 (Beleidsregels VOG-NP-RP 2018) and ss28 to 39 of the Judicial and Criminal Record Act (Wet justitiële en strafvorderlijke gegevens)
- In Denmark, Norway and Sweden, we will conduct criminal records checks for all grades of consultant using approved third party providers. We undertake this processing on the basis of your consent pursuant to section 8(3) of the Danish Data Protection Act.
Automated decision making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Sharing your information with third parties
We will only share your personal information with third parties for the purposes of processing your application, for example, search consultancies, recruitment agencies, third party test and assessment providers, screening and reference agencies as well as other PA group entities and IT providers who store data on our behalf. All our third-party service providers and other entities in the PA group take appropriate security measures to protect your personal information in line with Data Protection Legislation and PA policies.
Additionally, if you are referred by a PA person, that person will be able to see the status of your application at a high level. This status is limited to “lead”, “In progress”, “Hired” or “Didn’t work out”.
International transfer of your data
Your personal data will be stored in the EU and UK. Personal data relating to candidates within the EU or UK will only be accessible from the UK and EU. The European Commission has determined that the UK provides an adequate level of protection for your personal information. Likewise, the UK recognises the adequacy of the data protection standards in force throughout the EEA.
Information about candidates in the US will be accessible from the US as well as from the UK and EU.
We have appropriate security measures in place to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed as well as dealing with actual and suspected data security breaches. You can ask for further details of these measures from the contact details at the end of this notice.
We will store your personal information in accordance with the following list, subject to the country of collection:
- UK (including NI)/ EU (other than Netherlands): If you are successful, it will be stored in your employee record file in accordance with PA’s GDPR Privacy Notice For Employees, Workers and Contractors. If you are unsuccessful, it will be stored for 6 months after we have communicated our decision whether to appoint you to the role save that in Northern Ireland information about your gender and Catholic/Protestant community membership (or membership of neither) will be stored for three years from the date of receipt according to the Fair Employment (Monitoring) Regulations (Northern Ireland) 1999.
- Netherlands: If you are successful, it will be stored in your employee record file. If you are unsuccessful, for 6 months after we have communicated our decision whether to appoint you to the role.
- United States: If you are successful, it will be stored in your employee record file. If you are unsuccessful, for 12 months after we have communicated our decision whether to appoint you to the role.
Your data rights
Under certain circumstances, by law you have the right to: Request access to your personal information; Request correction of the personal information that we hold about you; Request erasure of your personal information; Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes; Request the restriction of processing of your personal information; Request the transfer of your personal information to another party and the right to withdraw your consent to processing of personal data where this is the lawful basis for our use of the data (including in respect of Diversity Data, save to the extent we are legally required to collect it).
If you would like to exercise any of the above rights, please use the email address at the end of this notice.
Concerns & questions; your right to complain
The PA group of companies is a worldwide management and technology consulting business based at 10 Bressenden Place, London, SW1E 5DN. If you have any concerns or questions about how we are using your data or if you would like to contact us about the content of this notice you can contact us at email@example.com. In the UK, you have a right to complain to the Information Commissioner (https://ico.org.uk/) if you are unhappy or have any concerns about the way we are processing your data. Other countries will have similar bodies who can give you advice.
Assistance for disabled applicants
Alternative formats of this Notice are available to individuals with a disability. Please contact firstname.lastname@example.org for assistance.
“Data Protection Legislation” means: to the extent the UK GDPR applies, the law of the United Kingdom or of a part of the United Kingdom which relates to the protection of Personal Data; and to the extent the EU GDPR applies, the law of the European Union or any member state of the European Union to which the Candidate is subject, which relates to the protection of personal data.