DATA PROTECTION STANDARDS

Pacific Talent Partners is an Australian-owned Executive Talent Consultancy focused on delivering solutions for our clients across the whole talent management lifecycle. We deliver these solutions through our three core service offerings; Executive Search, Interim Solutions and Talent Consulting.

Given the importance of safeguarding and keeping your information up-to-date, Pacific Talent Partners is committed to protecting the privacy of the Personal Data of its employees, customers, business partners, and other individuals worldwide. The following describes our firm’s policy regarding the collection, use, and transfer of Personal Data.

1. Objective and Scope
   The purpose of these Data Protection Standards is to provide consistent safeguards for the processing of the Personal Data of all stakeholders worldwide.
   • Processing refers to any human manual or automated action performed on Personal Data by Pacific Talent Partners. This includes, but is not limited to: recording, organizing, storing, modifying, disseminating, transferring, disclosing, deleting, and sharing such data among the Pacific Talent Partners group in accordance with Pacific Talent Partners policies.
   • Stakeholders refers to employees, customers, business partners, candidates, and other individuals worldwide that Pacific Talent Partners engages with.
   • Personal Data is any information about a stakeholder originally collected or otherwise used by Pacific Talent Partners in the context of a search or assessment assignment. Personal Data includes, but is not limited to: stakeholder name, contact information, professional experience, academic qualifications, skills, etc.

   Please note these Standards do not apply to any Personal Data that has been anonymised and used in the aggregate such as compiling industry and employment statistics where such data does not involve personally identifying information and individuals are not identifiable from it.

2. Pacific Talent Partners Global Standards & Local Laws
   Pacific Talent Partners currently operates throughout the world. Regardless of the jurisdiction, Pacific Talent Partners is required to abide by these Standards through the creation of a Declaration. Doing so protects the Personal Data processed by Pacific Talent Partners in countries that possess less rigorous protection than those contained in these Standards. Pacific Talent Partners will ensure that any new entities formed after the creation of these Standards will abide by the protections described herein. Of course, where certain countries in which Personal Data is processed employ more stringent regulations than those contained in these Standards, Pacific Talent Partners will naturally comply with those more stringent regulations.
3. Processing Personal Data
   Pacific Talent Partners Standards require the following with regard to processing Personal Data:
   • Personal Data is processed fairly and lawfully;
   • Personal Data is processed for legitimate purposes associated with Pacific Talent Partners services (“Purposes”);
   • Personal Data is not processed in any manner incompatible with these Purposes;
   • Personal Data is always relevant to the Purposes for which the Personal Data is obtained;
   • Personal Data is only used by Pacific Talent Partners and is not sold or shared for related or unrelated purposes to non-licensed third parties unless otherwise stated at the time of collection or as required by law;
   • Personal Data is processed and maintained in a manner that assures reasonable accuracy;
   • Personal Data that is inaccurate is corrected, updated, or deleted within a reasonable time of the discovery of the inaccuracy;
   • Personal Data is stored only for the duration necessary to fulfill these Purposes;
   • Personal Data is protected by all necessary and appropriate protective measures – both technological and legal;
   • Personal Data will not be automatically processed in any manner which will have a significant effect on the data subject except where authorized by a law which also safeguards the data subject’s legitimate interests; and,
   • Personal Data will not be transferred to third parties without adequate protections in place unless an exception permitting such transfers applies.
4. Purposes for Personal Data Processing
   Pacific Talent Partners processes and disseminates Personal Data only for its own use, only for legitimate Purposes, and in accordance with applicable laws. Such Purposes include:
   • Board, Executive and Management Search: Pacific Talent Partners processes and disseminates Personal Data in order to match candidates who are qualified for a particular position with client organisations who have an opening for such a position. Examples of processing for this purpose include, but are not limited to: collecting data from the candidate directly, performing background searches with the candidate’s consent, relaying Personal Data to a client with the candidate’s consent, and receiving referrals from individuals associated with the candidate.
   • Assessment Services: Pacific Talent Partners processes and disseminates Personal Data in order to evaluate the efficiency, productivity, and benefits of a client organisation at the client’s request. Examples of processing for this purpose include, but are not limited to, collecting data from a candidate directly, administering tests and assessing the candidate’s results, relaying Personal Data to a client with the candidate’s consent, and receiving referrals and evaluations from individuals associated with the candidate.
   • Information Sharing Globally Within Pacific Talent Partners: Pacific Talent Partners operates in a global marketplace and collects and disseminates Personal Data within and across its network for the purposes of Executive, Board, and Management Search and Executive Assessment Services as described above. This will involve the collection of Personal Data on candidates and the storage of that information in secure data centres in Australia, the United Kingdom or the United States, which is then accessible by all Pacific Talent Partners entities worldwide.
     
     
5. Security, Confidentiality and Enforcement
   Pacific Talent Partners will take all necessary and appropriate protective measures to prevent unauthorised access, loss, or damage to Personal Data and to ensure any
   processing of Personal Data is done in accordance with these Standards. Those measures include:
   • Employee Contracts and Policies: All employees of Pacific Talent Partners who have permanent or regular access to Personal Data, who are involved in the collection of Personal Data or in the development of tools used to process Personal Data are trained in these Standards and the best practices of handling such data.
   • Training: All employees of Pacific Talent Partners who have permanent or regular access to Personal Data, who are involved in the collection of Personal Data or in the development of tools used to process Personal Data are trained in these Standards and the best practices of handling such data.
   • Access Security: Personal Data is securely stored and can only be accessed via Pacific Talent Partners proprietary software. Access is continually monitored and restricted to employees of Pacific Talent Partners and is secured by appropriate physical, electronic, and managerial security procedures to prevent unauthorised access, loss, or damage to Personal Data.
   • Contractor Obligations: All Contractors performing services for Pacific Talent Partners must execute a written service contract. Beyond business terms, these service contracts include confidentiality and security obligations and data protection provisions and provide enforcement mechanisms through all available legal remedies.
   • www.pacifictalentpartners.com Safeguards: To safeguard all Personal Data that is submitted by candidates via www.pacifictalentpartners.com, appropriate physical, electronic, and managerial security procedures have been put in place to prevent unauthorised access, maintain the accuracy of data and ensure proper use of information via pacifictalentpartners.com.
   • Candidate Consent: All candidates are required to provide consent before any Personal Data will be disclosed to a client organisation or other third party.
6. Required Processing
   In situations where Personal Data must be disclosed as a matter of law, Pacific Talent Partners will use its best efforts to lawfully resist, limit, or delay disclosure and will ensure that only the Personal Data that is necessary and relevant to the request is provided. In the event that Pacific Talent Partners becomes aware of any legislation applicable to it which is likely to have a substantial adverse effect on the ability of Pacific Talent Partners to comply with these Standards, Pacific Talent Partners will determine a suitable course of action aimed at ensuring compliance with these Standards in consultation with the relevant Data Protection Authority.
7. Stakeholder Rights of Access, Rectification and/or Deletion
   At any time, in accordance with local laws, stakeholders may contact Pacific Talent Partners and inquire about their Personal Data. Requests by stakeholders for access to their Personal Data, for revisions, or for Pacific Talent Partners to cease processing of Personal Data can be made via email to privacy@ptpaustralia.com. The Privacy Officer for Pacific Talent Partners will coordinate all revisions or deletions of Personal Data. Upon request, Pacific Talent Partners will compile the information and provide it to a stakeholder. The stakeholder may request a revision of his or her Personal Data if it is incomplete or contains inaccuracies. Pacific Talent Partners updates or revises the Personal Data as the situation or law requires. A stakeholder may also request that their Personal Data no longer be processed. All requests to stop the processing of stakeholders Personal Data will promptly be honoured by Pacific Talent Partners and, unless otherwise noted in the request, will apply to all forms of processing by Pacific Talent Partners.
8. Stakeholder Enforcement Rights and Mechanisms
   Any person may inquire as to the nature of the data stored or processed about them by Pacific Talent Partners. Any Pacific Talent Partners employee contacted regarding such a request will direct the request to the Privacy Officer. The Privacy Officer will contact the individual directly and will remain in contact with the individual while the handling of the request is ongoing. If the stakeholder believes his or her Personal Data is being processed in contravention of these Standards, the stakeholder may report the concern to the Privacy Officer at privacy@ptpaustralia.com. Should the stakeholder and Privacy Officer be unable to resolve the dispute within six months, the candidate can seek remedies under the relevant laws.
9. Internal Oversight Procedures
   To verify compliance with these Data Protection Standards, Pacific Talent Partners will administer regular internal audits and report any issues or instances of non-compliance to the Pacific Talent Partners Board of Directors and implement methods for ensuring corrective measures. To the extent that such matters cannot be adequately handled within Pacific Talent Partners own resources, Pacific Talent Partners may appoint an independent third party to conduct an investigation/audit of any of the procedures or issues involving its Data Protection Standards.
10. Communication of Standards
    These Standards will be published at www.pacifictalentpartners.com. Employees are trained to adhere to these Standards and to follow the appropriate protocol.
11. Modification of Standards
    Pacific Talent Partners reserves the right to modify these Standards as needed. Where local law requires a higher standard for Personal Data it will take precedence over these Standards. Should Pacific Talent Partners make any substantive modifications to these Data Protection Standards, the changes will be promulgated throughout the business. Stakeholders will be informed going forward and have access to the updated Data Protection Standards at www.pacifictalentpartners.com.
12. Obligations to Data Protection Authorities
    Pacific Talent Partners will respond diligently and appropriately to all requests from data protection authorities regarding these Standards, including consenting to requests by a competent Data Protection Authority to audit Pacific Talent Partners compliance with these Standards. Pacific Talent Partners will abide by the advice of the Data Protection Authorities on any issues related to the interpretation and application of Pacific Talent Partners Data Protection Standards. Upon request, the Data Protection Authority shall receive a copy of any compliance audits conducted by Pacific Talent Partners regarding these Standards and Pacific Talent Partners will further comply with requests by the Data Protection Authorities for additional review of company-wide compliance.