1. General information
PRIVACY STATEMENT This global privacy statement explains how Accenture PLC and/or its affiliates, subsidiaries and newly acquired companies (“Accenture”) protect the personal data Accenture processes and controls relating to you (“your personal data”), why Accenture processes your personal data, who has access to your personal data and how you can exercise your rights in relation to the processing of your personal data.
Any Accenture entity located outside the European Union will for the purposes of compliance with data privacy laws be represented by Accenture PLC.
This global privacy statement provides an overview of Accenture’s most common processing activities of your personal data. Please note that certain specific processing activities may be subject to a separate and tailored privacy statement.
In the event any translation of this global privacy statement is prepared, the English version of this global privacy statement shall prevail in case of conflicts between the different language versions.
Which categories of personal data does Accenture process?
Accenture will collect personal data about you to achieve the purposes set out in this global privacy statement.
For further information on the specific categories of personal data Accenture is processing, please see section 2. For further information on the sources from which Accenture has obtained your personal data, please see section 3.
If you provide Accenture with any personal data of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this global privacy statement and that the person has given you his/her consent for sharing the information with Accenture.
Except for certain information that is required by law, your decision to provide any personal data to Accenture is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide Accenture with your personal data. However, please note that if you do not provide certain information, Accenture may not be able to accomplish some or all of the purposes outlined in this global privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data.
Why does Accenture process your personal data?
Accenture may collect, use, transfer, disclose and otherwise process your personal data in the context of facilitating communication with you (including in case of emergencies), operating and managing Accenture’s business operations, complying with legal requirements, monitoring your use of Accenture’s systems, undertaking data analytics and recruitment. For a more detailed list of the purposes, please see section 4.
Accenture will not use your personal data for purposes that are incompatible with the purposes listed in this global privacy statement, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.
On which legal basis does Accenture process your personal data?
Accenture processes your personal data as permitted by applicable data privacy laws and its internal policies.
Accenture processes your personal data for the purposes set out in this global privacy statement for one or more of the following reasons: (i) because Accenture is required to do so for compliance with a legal obligation to which it is subject, (ii) because such information is necessary for the performance of a contract to which you are a party, (iii) because the processing is necessary for the purposes of the legitimate interests pursued by Accenture or by a third party (as described in the last sentence of this paragraph), or (iv) where necessary in order to protect the vital interests of any person. Accenture has legitimate interests in collecting and processing personal data, for example: (1) to ensure that Accenture’s networks and information are secure, (2) to administer and generally conduct business and (3) to prevent fraud.
In addition, Accenture may process your sensitive data and/or make automated decisions concerning you where permitted by applicable law and/or with your prior consent and for the purposes mentioned in this privacy statement.
Please see section 5 for further information on the legal basis on which Accenture bases the processing of your personal data for each processing activity.
Who has access to your personal data?
Access to your personal data within Accenture will be limited to those employees who have a need to know the information for the purposes described in this global privacy statement, which may include personnel in Security, HR, IT, Compliance, Legal, Finance and Accounting, Corporate Investigations and Internal Audit. All employees within Accenture will generally have access to your business contact information (e.g. name, position, telephone number and e-mail address).
Furthermore, your personal data may be transferred to other Accenture offices and third parties, which may involve transferring your personal data to other countries.
As a global organization with offices and operations throughout the world, your personal data may be transferred or be accessible internationally throughout Accenture’s global business and between its entities and affiliates. Any transfers of your personal data to other Accenture offices (including transfers from within the European Economic Area (EEA) to outside the EEA) will be governed by Accenture’s binding corporate rules (BCR; a copy of which can be found here). Accenture’s BCR reflect the standards contained in European data privacy laws (including the General Data Protection Regulation). Having the BCR means that all Accenture’s group entities which have signed up to the BCR have to comply with the same internal rules. It also means that your rights stay the same no matter where your data are processed by Accenture.
Furthermore, where there is a need, Accenture may share your personal data with third parties, such as service providers and public authorities. Before doing so, Accenture takes steps to protect your personal data. Any third party service providers and professional advisors to whom your personal data are disclosed, are expected and required to protect the confidentiality and security of your personal data and may only use your personal data in compliance with applicable data privacy laws. For the categories of third parties with which Accenture may share your personal data, please see section 6. Unless you are otherwise notified, any transfers of your personal data from within the EEA to third parties outside the EEA will be based on an adequacy decision or are governed by the EU standard contractual clauses (a copy of which can be obtained from Accenture’s Data Privacy Officer). Any other, non-EEA originating, international transfers of your personal data, will take place in accordance with this privacy statement the appropriate international data transfer mechanisms and safeguards.
How does Accenture protect your personal data?
Accenture maintains organizational, physical and technical security arrangements for all the personal data it holds. Accenture has protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing Accenture undertakes.
Accenture adopts market leading security measures to protect your personal data. This includes (without being limitative):
- Accenture holds an ISO27001 certification, which indicates that it adheres to the highest and strictest information security standards. This is a security standard awarded by the British Standards Institution that serves as international certification that Accenture adheres to the highest and strictest standards. This certification is the only auditable international standard that defines the requirements for an Information Security Management System, and confirms that Accenture’s processes and security controls provide an effective framework for protecting its clients’ and its own information.
- Accenture has a global Client Data Protection program in place which governs the stewardship of client information and systems entrusted to Accenture.
- Accenture has regular penetration testing performed by a third party provider, which continues to show the strength of its technical defenses.
How long does Accenture retain your personal data?
Accenture retains your personal data only for as long as is necessary. Accenture maintains specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:
- Accenture retains your personal data as long as it has an ongoing relationship with you.
- Accenture retains your personal data for as long as needed in order to comply with a legal obligation to which it is subject.
- Accenture retains your personal data where this is advisable to safeguard or improve Accenture’s legal position (for instance in relation to statutes of limitations, litigation, or regulatory investigations).
Please keep your personal data at all times up to date and inform Accenture of any material changes to your personal data.
Which rights do you have concerning your personal data?
Please contact Accenture’s Data Privacy Officer if you (i) have any questions or concerns about how Accenture processes your personal data or (ii) want to exercise any of your rights in relation to your personal data.
You have the right (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law to:
- Request access to the personal data we process about you: This right entitles you to know whether Accenture holds personal data of you and, if so, obtain information on and a copy of those personal data.
- Request rectification of your personal data: This right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
- Object to the processing of your personal data: This right entitles you to request that Accenture no longer processes your personal data.
- Request the erasure of your personal data: This right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
- Request the restriction of the processing of your personal data: This right entitles you to request that Accenture only processes your personal data in limited circumstances, including with your consent.
- Request portability of your personal data: This right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to Accenture, or request Accenture to transmit such personal data to another data controller.
To the extent the processing of your personal data falls in scope of Accenture’s BCR, you may also want to review your rights under Accenture’s BCR.
To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting Accenture’s Data Privacy Officer. Please note that this will not affect Accenture’s right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.
Please note, however, that certain personal data may be exempt from the above-mentioned rights pursuant to applicable data privacy or other laws and regulations.
If, despite Accenture’s commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome you to come to Accenture first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against Accenture with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed).
What if you have questions or want further information?
This global privacy statement, and the web pages referred to therein, aims to give you complete and transparent information on how Accenture processes your personal data.
If you have any further questions or concerns regarding how Accenture processes your personal data, or if you wish to exercise any of your foregoing rights, please contact the Data Privacy Officer.
2. Further information on categories of personal data
The below table sets out the categories of personal data that Accenture processes or may process in the context of the processing activities described in the global privacy statement.
|Category of personal data||Explanation|
|Personal details.||Name, preferred pronoun, all types of contact details (such as e-mail, phone numbers, physical address), gender, date of birth, age, place of birth.|
|Sensitive Data.||Accenture may also collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status and dietary requirements/allergies in the framework of the events we organize/sponsor). Accenture will only use such sensitive information for the purposes described in section 4.|
|Audiovisual materials.||Photograph, and images/footage captured on CCTV or other video and related security/monitoring systems.|
|Position.||Description of current position, job title, employer, location, Accenture contact(s).|
|System and application access data.||Where you are provided with access to Accenture’s systems, Accenture may collect information required to access such Accenture systems and applications such as System ID, LAN ID, e-mail account, instant messaging account, mainframe ID, system passwords, access logs, activity logs, and electronic content produced using Accenture systems.|
In addition, for recruitment purposes, Accenture may process the personal data set out in the below table.
|Personal details.||In addition to the personal details listed above, Accenture may collect additional personal details for recruitment purposes, such as national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, military history.|
|Sensitive data.||Accenture may collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and (where authorized by law) information on criminal convictions and offences. Accenture collects this information for specific purposes, such as health/medical information in order to accommodate a disability or illness and to provide benefits; background checks; religion or church affiliation in countries such as Germany where required for statutory tax deductions; and diversity-related personal data (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination.|
|Documentation required under immigration laws.||Accenture may collect data on citizenship, passport data, details of residency or work permit (a physical copy and/or an electronic copy).|
|Talent management information.||Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies.|
3. Further information on sources of personal data
Your personal data have been obtained by Accenture from the sources set out in the below table.
|Source from which Accenture obtains the personal data|
|Employers of the visitors and contractors.|
|Public websites and social media.|
|Suppliers and vendors.|
In addition, for recruitment purposes, Accenture may obtain personal data from the sources set out in the below table.
|Background check providers.|
|Talent management providers.|
The above sources are private sources, unless where the source is expressly stated to be “public”. Note that these sources may have been holding your personal data both inside and outside the EU.
4. Further information on the purposes
As set out in the global privacy statement, Accenture processes your personal data for multiple purposes. The below table sets out each of the purposes for which Accenture processes your personal data.
|Facilitating communication with you (including in case of emergencies).||Facilitating communication with you, ensuring business continuity, protecting the health and safety of employees and others, safeguarding IT infrastructure, office equipment and other property, facilitating communication with you and your nominated contacts in an emergency.|
|Operating and managing Accenture’s business operations (including security).||Operating and managing the IT and communications systems, IT security operations, security access control to facilities, managing Accenture assets, business continuity and disaster recovery, compilation of audit trails and other reporting tools, maintaining records relating to business activities and organizing Accenture events/seminars.|
|Monitoring your use of Accenture’s assets||Monitoring activities as permitted by local law and/or in accordance with applicable Accenture policies (including monitoring the use of Accenture resources).|
|Undertaking data analytics.||Applying analytics to business operations and data to describe, predict and improve business performance within Accenture and/or to provide a better user experience. Specifically, areas within analytics include descriptive analytics, predictive analytics, analytics involving individuals (clients, business contacts) use personal data, analytics driven by marketing, single customer view and customer journey and workplace analytics.|
|Recruitment.||Managing job applications, including conducting interviews, undertaking appraisals, assessing performance, financial planning, undertaking payment administration, managing inclusion and diversity programs, performing background checks, planning and monitoring training requirements.|
5. Further information on legal basis
Accenture processes your personal data based on the legal bases set out in the below table.
|Facilitating communication with you (including in case of emergencies).||Justified on the basis of Accenture’s legitimate interests for ensuring proper communication and emergency handling within the organization.|
|Operating and managing Accenture’s business operations (including security).||Justified on the basis of Accenture’s legitimate interests for ensuring the proper functioning of its business operations.|
|Complying with legal requirements.||Necessary for the compliance with a legal obligation to which Accenture is subject.|
|Monitoring your use of Accenture’s systems.||Justified on the basis of Accenture’s legitimate interests of avoiding non-compliance and protecting its reputation.|
|Undertaking data analytics.||Justified on the basis of Accenture’s legitimate interests of analyzing and improving the proper functioning of its business operations.|
|Recruitment.||Justified on the basis of Accenture’s legitimate interests for ensuring that it recruits the appropriate employees.|
Please note that:
- Where the above table states that Accenture relies on its legitimate interests for a given purpose, Accenture is of the opinion that its legitimate interests are not overridden by your interests, rights or freedoms given (i) the transparency Accenture provides on the processing activity, (ii) Accenture’s privacy by design approach, (iii) Accenture’s regular privacy review and (iv) the rights you have in relation to the processing activity. If you wish to obtain further information on this balancing test approach, please contact Accenture’s Data Privacy Officer.
- Where any of the above purposes require the processing of sensitive data, Accenture will only do so where permitted under applicable law, or with your prior consent.
- Where any of the above purposes involve an automated decision, Accenture will only make such automated decision with your prior consent and after having informed you of meaningful information about the logic involved in the automated decision, as well as the significance and the envisaged consequences of such automated decision for you.
- Accenture will process your personal data based on your prior consent to the extent such consent is required by mandatory law.
6. Further information on categories of third party recipients
In addition to transferring personal data to its affiliates and relevant internal staff, Accenture may also transfer your personal data to the categories of unaffiliated third parties set out in the below table.
|Category of third party||Explanation|
|Professional advisors.||Accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors in all of the countries in which Accenture operates.|
|Service providers.||Companies that provide products and services to Accenture such as IT systems suppliers and support, trade bodies and associations, and other service providers.
For recruitment purposes, Accenture may also transfer your personal data to companies that provide products and services to Accenture in relation to performance, training, expense management, and background searches.
|Public and governmental authorities.||Entities that regulate or have jurisdiction over Accenture such as regulatory authorities, law enforcement, public bodies, and judicial bodies.|
|Corporate / commercial transaction.||A third party in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Accenture business, assets or stock (including in connection with any bankruptcy or similar proceedings). A third party in connection with any proposed or actual client project.|
7. Contact us
You can contact Accenture as data controller of your personal data via our Data Privacy Officer (preferably electronically) or via post, clearly marked for the attention of the Data Privacy Officer, on this address: Accenture Limited Dublin, 1 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.