EU/UK Recruitment Privacy Notice
1 Scope of privacy notice
Like most businesses, we hold and process a wide range of information, some of which relates to individuals who are applying to work for us. This Recruitment Privacy Notice (“Notice”) explains the type of information we process, why we are processing it and how that processing may affect you. It focuses on individuals who are applying to work for us and the data we process as part of that process.
Please note that if you accept an offer from us the business will process further information as part of the employment relationship, and we will provide you with our Workplace Privacy Notice for employees and other workers as part of the on-boarding process.
Omnicom Health Group are a global group of communications, marketing and consulting companies specializing in the healthcare sector. In this notice ‘we’, ‘us’ and ‘our’ refers to the relevant company that acts as the ‘data controller’ in respect of your personal data, a list of which is set out in the Annex of this document. ‘Data controller’ means the person that determines the purposes and means for which your personal data is processed. In the context of this notice, the relevant data controller of your personal data is the company which you apply to work for.
In the Supplementary Information section below, we explain what we mean by “personal data”, “processing”, “special personal data” and other terms used in the notice.
In brief, this Recruitment Privacy Notice explains:
- what personal data we hold and why we process it;
- the legal grounds that allow us to process your personal data;
- where the data comes from, who gets to see it and how long we keep it;
- how to access your personal data and other rights; and how to contact us.
Finally, this Recruitment Privacy Notice is only intended to meet the requirements of:
- Regulation (EU) 2016/79 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“EU GDPR”).
- Equivalent data protection laws in the United Kingdom (the “UK GDPR”).
Where other privacy laws (other than the EU GDPR and the UK GDPR) apply, please see our General Privacy Notice.
2 Personal data – what we hold and why we process it
We hold various types of data about the individuals who apply to work for us, including their personal details and work history. Further examples of the types of data we hold are given in the Supplementary Information below.
We process this data for the purposes of our business, including management, administrative, employment and legal purposes. The Supplementary Information section provides more specific information on these purposes.
3 Where the personal data comes from and who gets to see it
Some of the personal data that we process about you comes from you. For example, you tell us your contact details and work history as part of the recruitment process. If you are joining us, you may provide your banking details.
Other personal data may come from third parties such as recruiters acting on your behalf or from your references.
Your personal data will be seen internally by managers, HR and, in some circumstances (if you join us) colleagues. We will where necessary and as set out in this notice also pass your data outside the organisation, for example to people you are dealing with and background checking agencies.
Specific circumstances in which your personal data may be disclosed include:
- organisations and service providers that process data on our behalf e.g. third parties that provide or host our websites, IT systems and information (e.g. our email provider);
- third party recruitment consultants and similar businesses (including online recruitment portals) as a part of the recruitment process, particularly where you have applied to us via a recruiter or third party website;
- referees, in connection with our referencing processes;
- group companies (e.g. where information is shared internally in connection with your application);
- disclosure of aggregated and anonymised diversity data to relevant regulators as part of a formal request;
- to a third-party organisations in connection with a potential or actual business transaction (e.g. a merger or acquisition).
4 How long do we keep your personal data?
In general, we only keep your data for as long as necessary for the purpose for which it was collected and in accordance with the following retention periods:
- Successful candidates: if you become employed by us we will keep your personal data for the duration of your employment with us and then for a certain period of time thereafter (further information will be provided in our Workplace Privacy Notice).
- Unsuccessful candidates: if you are unsuccessful in gaining employment with us, we usually keep your personal data associated with your application for up to 12 months from the date that we received your application (unless a different retention timeframe is required by law), and unless you agree that we can retain it for longer (in which case we retain the information for such longer period that you have agreed to).
We will retain your name, email address, and application outcome for a further 24 months in order to maintain a record of your application for internal administrative purposes (e.g., tracking re-applications and/or avoiding duplication).
- Other information: certain other information collected in connection with the recruitment process, may be kept for a shorter time period (e.g. CCTV footage data if you attend our premises for an interview) which we will store and delete such data in accordance with our internal retention policies.
In certain limited cases, we may keep your personal data for different periods of time including for periods of time that may not have a finite retention period where such period of time will depend on particular circumstances relating to your personal data (e.g. in the event that it relates to a legal claim). Where there is no finite retention period we take into account the following criteria in order to determine how long to retain your personal data including the relevance and usefulness of the personal data to our business and any legal obligations or interest in we have in retaining your personal data (e.g. to exercise or defend against a potential claim).
5 Transfers of personal data outside the EEA and United Kingdom
We may transfer your personal data outside the EEA and/or United Kingdom, in particular to members of our group in the United States, and to other third-party service providers and other group companies located in both adequate and non-adequate countries for data protection purposes (a country is considered “adequate” if it is subject to an adequacy decision which is recognised by the UK).
Where we transfer your personal data to a non-adequate country, we will ensure appropriate safeguards are in place (e.g. standard contractual clauses). You can obtain a copy of these safeguards by contacting us using our contact details set out below in this notice.
6 Your personal data rights
You have various rights in relation to the personal data we hold about you, including:
Right to make a subject access request
You have the legal right to make a “subject access request”. If you exercise this right and we hold personal data about you, we are required to provide you with information about it, including giving you a description and copy of the personal data and telling you why we are processing it.
Other rights
You may have a legal right to have your personal data rectified or erased, to object to its processing or to have its processing restricted. If you have provided us with data about yourself (for example your address), you have the right to be given the data in machine readable format, including to have it transmitted to another data controller (this only applies if the ground for processing is Consent or Contract, as defined in the Annex).
If we have relied on Consent as a ground for processing, you may withdraw your consent at any time but doing so will not affect the lawfulness of our processing of your personal data which we conducted on the basis of your consent prior to you withdrawing it.
Right to complain
If you have a complaint relating to our processing of your personal data, you should raise these with your contact in the recruitment team in the first instance or with our Data Protection Officer.
You also have the right to lodge a complaint with the supervisory authority for data protection in your country.
7 Contact details
Our contact details and those of our data protection office are as follows:
Omnicom Health Group
Attn: Data Protection Office
200, Varick Street,
New York,
NY, 10014, United States
8 Status of this notice
This Recruitment Privacy Notice does not form part of any contract of employment you might enter into and does not create contractual rights or obligations. It may be amended by us at any time. Nothing in this notice is intended to create an employment relationship between us and any non-employee.
Annex: Supplementary information
List of data controllers
| Company Name | Address |
| 2TheNth Limited | Adelphi Mill, Grimshaw Lane, Bollington, Macclesfield, Cheshire, SK10 5JB, England |
| Adelphi Communications Limited | Adelphi Mill, Grimshaw Lane, Bollington, Macclesfield, Cheshire, SK10 5JB, England |
| Adelphi Group Limited | Adelphi Mill, Grimshaw Lane, Bollington, Macclesfield, Cheshire, SK10 5JB, England |
| Adelphi International Research Limited | Adelphi Mill, Grimshaw Lane, Bollington, Macclesfield, Cheshire, SK10 5JB, England |
| Adelphi Values Limited | Adelphi Mill, Grimshaw Lane, Bollington, Macclesfield, Cheshire, SK10 5JB, England |
| Chameleon Communications International Ltd | Bankside 2, 90 – 100 Southwark Street, London, SE1 0SW, England, United Kingdom |
| DDB Health Barcelona, S.L. | Carrer de Felip II, 108, 08027 Barcelona, Spain |
| DDB Health GmbH | Blumenstraße 28, 80331 München, Germany |
| DDB Remedy Limited | Bankside 2, 90 – 100 Southwark Street, London, SE1 0SW, England |
| Excerpta Medica B.V. | 4, Prof W.H. Keesomlaan, Amstelveen, 1183 DJ, Netherlands |
| Grupo CDM Spain, S.L.U. | Calle Felipe II, numero 108, Planta 1, 08027 Barcelona, 08027, Spain |
| Synergy Medical Communications Limited | Bankside 2, 90 – 100 Southwark Street, London, SE1 0SW, England, United Kingdom |
| TBWA\WorldHealth London Limited | Bankside 2, 90 – 100 Southwark Street, London, SE1 0SW, England |
| The Planning Shop International Limited | 12, Bishop’s Bridge Road, London, W2 6AA, England |