Your Privacy Matters

Our Privacy Principles

Burnham Rosen Group and its subsidiaries and affiliates (“BRG”, “us” or “we”) are committed to respecting your privacy and protecting your personal information. This privacy notice describes:

  • What kinds of information we collect and how;
  • For what purposes;
  • How we handle and protect your information;
  • Your rights and options regarding your personal information.

As used in this privacy notice, “Personal Information” means information capable of identifying you as an individual or data specifically associated with information capable of identifying you as an individual.

We will process your Personal Information in accordance with this privacy notice, unless such processing conflicts with the requirements of applicable law, in which case, applicable law will prevail.

What kinds of information we collect and how we collect it

We collect personal information to provide our services to you, to our clients and to operate our business. The information we collect varies by situation or service. Information we collect may include:

As you interact with BRG, you may submit some information directly: We may collect Personal Information when you register to use our Online Systems; respond to employment opportunities; complete online assessments or surveys; provide Personal Information about yourself to our interviewers or coaches; or contact us via e-mail, electronic forms, telephone or postal mail.

We may collect information on your behalf in the course of conducting our Services: We may collect information for coaching or workshops, such as 360 feedback, in order to provide our Services to you or our Clients.

Personal Information about you may also come from our Clients to whom we provide services:

  • Clients may provide Personal Information about you in order to provide our Services, such as your contact details; location; title; names of your manager(s) and subordinates; recent roles and responsibilities, etc.
  • If you are participating in Selection Services for a Client Organization that wants to consider you for a role, we may collect information related to your consideration for the role sent to us by you or the Client, such as resumes; Curriculum Vitae; additional information that you have submitted to either the Client or to us or that has been made available to us by the Client to enable us to perform the Service.
  • Personal Information may also come from third parties: We may collect information about you from public sources such as LinkedIn.
  • Sensitive Personal Information is not requested by BRG at any point for the delivery of Services unless required by law or for specific research purposes. Sensitive Personal Information means Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.  In the event such information is collected, we will not share this information about an individual unless required by law.

How we use your Personal Information

We use Personal Information to manage our contractual and business relationship with you and our clients; to comply with a legal obligation; and where we have a legitimate beneficial business interest that makes its use necessary.

We use your Personal Information to respond to your inquiries and fulfill your requests. If you contact us, we keep a record of your contact information and correspondence, and we use information you provide in your message to respond to your inquiry. We do so to manage our legal, ethical and customer service relationship with you.

We may use your Personal Information to send you important information regarding our Online Systems or Services, such as changes in policies, terms and conditions, and other administrative updates.

We may use your Personal Information to send information such as white papers, articles, and information regarding our Services. If we obtained your Information as the result of a recruitment Service with our Clients, please note that we will not send you educational materials unless you specifically request to be included in such mailings.

We may retain and use your Personal Information for research, development, benchmarking, longitudinal studies and norms, to improve our services or develop new services:

  • In this case only aggregate or de-identified data is used so the end-product does not identify you or any other individual. For example, we may use this information to generate norms by industry, geography, level, etc., enable us to conduct on-going research studies, compile reports, and publish articles to further the knowledge base of organizational and leadership science. Such aggregated, anonymized or de-identified information is not considered Personal Information for purposes of this Policy and we may use it for any purpose.
  • We may anonymize or key-code your Personal Information, meaning that the information is stripped of all Personal Information that may directly identify you and is replaced with a code to minimize unintended identification to allow for activities such as aggregate data analysis. Such key-coded information can be de-coded by using the key so that it identifies you again.

How your Personal Information is stored

Your Personal Information is stored in our contact and research databases. It may also be stored in e-mails and documents maintained on our servers or on the computers or laptops of your coach, facilitator or client consultant.

Your information may also be stored on third-party servers as part of our data security and recovery maintenance. These third-parties have certified that they are in compliance with international data security and privacy laws such as GDPR.

Depending on the nature of the Service we are providing for you or our Client, information may be collected, used, processed, disclosed or transferred to and within countries where BRG have facilities or in which we engage service providers. Information may also be collected, processed, disclosed or transferred to and within countries where Clients have facilities or employees.  By using our Services, you understand that your Personal Information may be transferred to countries outside of your country of residence that may have different data protection rules than your country.

Who has access to your Personal Information

We use your Personal Information to provide our Services.  How your information is disclosed depends on the situation.

We may share your Personal Information with our international coaches and trainers in order to provide our Services to you and our Clients.

In providing services to our Clients – including workshops, coaching, recruitment services and development reports – we disclose Personal Information to our Clients. The Client can be your employer or an organization with whom you are seeking employment. The following conditions apply to our disclosure of Personal Information:

  • If you completed an Exercise of Imagination [EOI] for participation in a workshop, only the facilitators of the workshop you attend, and the BRG staff required to support them and any on-going Client advisory services, will have access to your personal results. Your EOI data is considered confidential and is not released to the Client or any other Client without a specific request and release from you.
  • If you completed an EOI for participation in a coaching or development engagement that involves co-creation of coaching goals with your manager, the EOI may be shared with your manager as part of that process. This would be specified in your coaching engagement contract.
  • In the course of the Recruitment Services we provide to Clients, we disclose Personal Information regarding candidates, including the results of the EOI, other assessments, interviews, and related data, to the prospective employer Client that has engaged us to fulfill recruitment requests. Your Personal Information will not be released without a specific request and release from you to any other Clients.
  • If you complete assessments or exercises on behalf of another individual or group, such as a 360 or culture survey, only aggregate data will be shared with the Client. Any individual responses by you that cannot be aggregated – such as comments – will be shared anonymously and/or in a manner that does not expose your identity.
  • If you participate in a succession planning engagement with your employer, you will be given the choice to opt-in and share your data with your employer as part of that engagement. Your EOI or other assessment data will not be shared without your specific consent.
  • Your Personal Information obtained through a coaching engagement is not shared with Clients and is considered Confidential. Unless this is a personal coaching engagement, however, our shared contract with your employer includes engagement with the coaching process.  Frequency of coaching meetings and your engagement with the coaching goals is sometimes shared with your manager or the Client.

We may also use or disclose Personal Information (to comply with a legal obligation or because we have legitimate interest to do so) in order to: (i) comply with applicable laws, (ii) respond to inquiries, requests or orders from public or government authorities, including those outside of your country of residence, or (iii) protect the rights, privacy, safety or property, of BRG and our affiliates, you or others.

BRG may also transfer your Personal Information in the event of a sale, merger, or acquisition.

We cannot and do not assume any responsibility for the actions or omissions of third parties, such as Clients, including the way they use Personal Information received either from us or from other independent sources.

Access and choices regarding your Personal Information:

Your provision of Personal Information is voluntary, however, if you do not provide Personal Information you may not be able to participate in our Services. If you decide not to provide Personal Information and that effects our ability to fulfill contractual obligations with our Client, we will be required to inform the Client.

You may contact us at privacy@burnrose.com to ask questions about how we handle your Personal Information, or to:

  • Request, review, correct, update, suppress or restrict the use of your Personal Information
  • Withdraw your consent for the use of your Personal Information
  • Request an electronic copy or review of your information
  • Object to the use of your Personal Information for our legitimate business purposes

Please ensure that such requests are accompanied by all relevant e-mails or user ids, etc. to enable us to respond to your request.  We will respond as soon as possible, no later than 30 days from receipt.

  • Please note that BRG uses backup systems. If you ask that your information be removed from our databases, we may not be able to delete residual copies from our systems or from our backup systems, but they will continue to be protected as required under this policy.

Other Information

BRG collects other information about you that does not reveal your identity.  This may include information collected through pixel tags, cookies, apps, demographics and aggregated information. Because other information does not reveal your personal identity, we may use it for any purpose.  If any of that information is combined with your Personal Information and thus is associated with your personal identity (IP address location, for example), it will be treated as Personal Information for as long as it is combined with all the protections maintained in this policy.

Security

BRG maintains and monitors security measures in order to protect against the loss, misuse, and alteration of your personal information under our control.  However, no electronic system is 100% secure.  If you have reason to believe your data is no longer secure, please contact us immediately at privacy@burnrose.com. If we discover a data-breach, we will make every effort to contact you at your last known e-mail or phone number within 48 hours of breach to inform you of the nature of that breach.

Data Retention

We retain your Personal Information for as long as is required in order to provide our Services to you or our Client, or if we have a legitimate internal operations need.  For example:

  • We retain your Personal Information for as long as we have an on-going relationship with you or the Client.
  • If there is a legal obligation or position, such as the need to retain the data for record keeping or compliance with data retention schedules or laws, applicable statues of limitations, litigation or regulatory advisories or laws.
  • A period beyond the time of the ongoing relationship if we have a legitimate internal operations need, such as a need to retain such information for analysis or record-keeping
  • To enable your development should you engage with us in the future in additional Services or track your development trajectory.

 

We review our policies regularly and they are subject to change.  Any changes to the Policy will become effective upon posting of the revised Policy on the Internet, accessible through the Site. This policy was last updated 17 July 2020.

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