Privacy Policy

Personal information we collect

Pebl collects information that identifies you as an individual (‘Personal Information’) to provide services to our clients and to operate our business. The type of Personal Information we collect about you depends on the service offering being delivered:

• During our services, we may collect Personal Information such as your: name, e-mail address, telephone number, location, first language, CV / Resume aspects (e.g. job title, work history, education) and references.
• If you are taking part in a Pebl process for either recruitment or development, we may ask if you would like to record your own demographic indicators (for example your age group, gender, ethnic background). This is used only for the purposes of statistical analysis in the field of diversity and inclusion and is not a part of any Pebl assessment. This information is completely voluntary in the case of an assessment service.
• For certain services a client may request demographic information to be included within the project reporting element in relation to our offering. We, in turn, may request this information from yourself. For instance, for services relating to diversity and inclusion agendas we may include demographic questions on: gender, race, age or ethnicity.
• If necessary, we will ask for information regarding your physical health for accessibility purposes.
• We do not require any other sensitive information from you, unless asked for in these limited situations. For instance, we will not ask for sensitive information relating to political opinions, as part of normal practise.
• With regard to referencing, we will store information about the referees we speak to, along with their written reference, for five years. We may collect the following information: dates and time working together, a reference about the person. We may also invite you to share biographical information such as gender and ethnic background.
• Please do not provide us with any Personal Information if you do not agree with this Policy.

How we collect personal information

As you interact with Pebl, you provide some Personal Information directly. We may collect Personal Information when you register to use our Online Platform, submit your CV, complete online surveys, psychometrics or 360s. If you submit Personal Information about other people to us, you represent that you have the authority to do so and permit us to use the information in accordance with this Policy.

Personal Information about you may also come from our clients to whom we provide Services. These clients may be your employer or an organisation with which you are seeking employment.

How we use the information we collect

Pebl uses the Personal Information collected to support the delivery of our Services. This information is held, used and disclosed by us as follows:

• Fulfilling client requests: to help Pebl to fulfil our contractual obligations with a client, where you may be a current or prospective employee of that client.
• Fulfilling your requests: to answer any questions you may have about Pebl, our processes or for any other request you may have.
• Analytics: we may retain and use Personal Information about you for benchmarking, creating norms, including validation studies, to improve and enhance our services or to develop new Services in the field of leadership development. The end product will be aggregated and anonymised and therefore is no longer considered Personal Information due to the fact that you cannot identify any individual. The norms we develop across particular industries, geography or levels, when compared with your own Personal Information, generate insights and form a significant part of the assessment and referencing offering for our clients.
• Third Party Sub-processors: Pebl use third parties, who comply with similar undertakings of privacy and confidentiality as Pebl, as they perform outsourced operational functions on our behalf and who also provide services to us. These organisations include:
• Technology operations companies who run Pebl’s IT or support Pebl’s systems.
• Psychometric Assessment Suppliers.
• Operating our Business: your name and date of the delivery of a service to a client may be included in such matters as client audits, internal communication, administering our services, procurement and financial transactions.
• Law: we may also release Personal Information to regulatory or law enforcement agencies, if they require us to do so. We will also disclose subject information where we are permitted and requested to do so by law.
• If we wish to use your information for any of the reasons not listed above, we will seek your explicit consent to collect, hold, use and disclose your Personal Information.

How Pebl works with you

As defined under GDPR, Pebl is a data controller. As we determine the purposes and means of processing Personal Information, this classifies us as a data controller. This relates to the way in which we work with our clients and with you.

Where a client has requested that Pebl provide a leadership consulting service to them which relates to you, this service will always be commissioned by our client with your knowledge and agreement. This service may be in relation to assessment and referencing (for recruitment, development or due diligence), coaching, workshops, psychometrics or other leadership consulting services.

At the beginning of Pebl’s engagement, we will ask for basic information like contact details. During an assessment process you will be asked, verbally, to share personal and career history with your assigned Pebl consultant. We will also ask you to complete psychometric profiling tests.

Your Pebl assessment report will make recommendations to our client about your potential and/or development profile. Your psychometric profiling data will form part of an overall assessment by the consultant. Where applicable, referencing will be integrated into the assessment report too. This assessment report is developed individually by the consultant and is not automated.

Whenever your record appears in an analysis from our benchmarking database, this will be in aggregated and anonymised form, and you will not be identifiable by the recipient of such an analysis. Pebl’s data subjects – individual Personal Information, and the benchmarking database, are not shared with any other organisations.

Who has access?

How your Personal Information is disclosed will depend upon the situation:

While providing our Services, we will disclose your Personal Information to our client who has engaged our services in relation to yourself. We will not share any of your Personal Information with any other client. Pebl discloses Personal Information to third parties who provide support for our Services of business operations. These include, but are not limited to, IT consulting services, and any audit administration firms commissioned.

Retention period of personal information

In general, we will retain your Personal Information for the necessary period to fulfil our purpose as defined by GDPR regulations. This is commonly a five-year retention period for our services, with our reports being valid for a two-year period. We will only retain information about you past this five-year retention point if it is necessary: such as your name, email address and why and when you used our services.

Location of personal information

Pebl is a UK consulting organisation, with staff in the United Kingdom and the EU. If you are a resident of the EU or the UK, your Personal Information may be transferred and processed to countries outside of the EU or UK, including the United States where our group company Pebl Inc. is located.

If we transfer your Personal Information to a country outside of the EU or UK, and that country is not covered by an adequacy decision from the European Commission or an adequacy regulation from the UK Secretary of State, we have taken appropriate safeguards to ensure that your Personal Information will remain protected in compliance with applicable EU and UK data protection laws and in accordance with this Privacy Policy. Specifically, we use the European Commission’s Standard Contractual Clauses (“SCCs”) for transfers of Personal Information outside the EU, and the UK International Data Transfer Addendum (“UK Addendum”) for transfers of Personal Information outside the UK. Pebl Services Ltd. and its group company Pebl Inc. has entered into an intragroup data transfer agreement based on the SCCs and UK Addendum which allows for the processing and transfer of EU/UK Personal Information to the United States.

Use of the internet

Given that the Internet is a global environment, the use of the Internet to collect and process Personal Information necessarily involves the transmission of data on an international basis. Therefore, by browsing our website and/or communicating electronically with us, you acknowledge and agree to our processing of Personal Information in this way.

Your choices regarding your information

The Personal Information you provide us is on a voluntary basis. Please note that if you do not wish to share some Personal Information with us, you may not be able to participate in our services.

Individuals located in the EU and UK have the following data protection rights:

• You have the right to access, correct, or request deletion of your personal information.

• You have the right to object to processing of your personal information, ask us to restrict processing of your personal information, or request portability of your personal information.

• If we have collected and processed your personal information based on your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

• You have the right to opt-out of marketing communications.

• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

If you wish to exercise any of the above rights, please refer to the contact details below. We may ask you to verify your identity, and to put your request in writing. We will respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Where we are unable to comply with your request, we will provide reasons for not doing so.

For example, please note that if your request involves deletion of your file, in some circumstances we may not be required or able to do so, particularly where your file also holds information about our clients or includes financial information that we need to keep for periods of up to five years.

Updates to our Privacy Policy

This Privacy Policy may be changed by Pebl at any time. If we change it in the future, we will advise you of changes or updates by a prominent notice on our website. Continued use of this website or our services after such changes will constitute your acceptance of such changes.

Contact us

If, at any time, you have questions or concerns about Pebl’s online privacy policy, please feel free to e-mail us at: finance@pebl.com or by writing to us at:

Aiden Walsh

Privacy Officer

Pebl Ltd

C/O FORA

One Lyric Square

Hammersmith

London

W6 0NB

United Kingdom

Last updated November 18, 2024