Privacy Notice
1.Purpose and Scope
In the regular course of business, Leadenhall Project Management, acquires Personal Information by interaction and communication with potential, current or past job applicants, alumni, talent networks, clients, vendors, contractors, sub-contractors and other third parties. Leadenhall takes serious, its obligations to protect such Personal Information. As evidence of its commitment to privacy, Leadenhall has established this Privacy Notice about how Leadenhall collects, uses, processes and stores your Personal Information.
Leadenhall will only process your Personal Information in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure the Personal Information collected about you is adequate, relevant, not excessive, and processed for limited purposes.
This Privacy Notice does not cover aggregate data, data rendered anonymous or data that has been deidentified. Aggregate data relates to a group or category of individuals, from which individual identities have been removed. Data is rendered anonymous if individual persons are no longer identifiable. Deidentified data is data that has had identifiable elements removed, and cannot reasonably identify, relate to, described, be capable of being associated with, or be linked, directly or indirectly, to a particular individual.
You are under no obligation to provide Personal Information to Leadenhall . However, if you do not provide the information, we may not be able to provide the requested service to you.
We may revise this Privacy Notice from time to time, and when we do so, we will update the “Revised” date below. If we make material changes to this Privacy Notice, we will notify you by email or by posting a notice on our website. We encourage you to periodically review this Privacy Notice to stay up to date on our privacy practices.
2. Data Collected and Purpose
The information below provides an overview of the Personal Information Leadenhall collects about you for purposes described herein.
Full Name, Telephone Number, Address, Email Address
Purpose:
a. Communicate with talent networks job applicants, clients, vendors, contractors, sub-contractors and other third parties concerning opportunities, projects and business operations.
b. Administer background/clearance checks, legal due diligence/anti-corruption screening, and quality, occupational health and safety standard checks on job applicants, vendors, contractors and sub-contractors.
c. To verify individual’s identity.
d. Recording of working time and timesheet records for contractors and sub-contractors.
e. Incident response communications with customers, vendors, contractors, subcontractors and other third parties.
f. Administration of safety and protection of LPM employees, resources, and workplaces.
Business Relationship Status
Purpose:
a. Ensuring access to correct areas is granted for customer staff, vendors, contractors and sub-contractors.
b. Identification purposes for physical site access and security.
c. Recording of working time/timesheet records for contractors and sub-contractors.
Emergency Contact Name and Telephone Number
a. Emergency contact use for contractors and sub-contractors.
Date of Birth, Nationality, Citizenship, Country of Birth
a. To administer eligibility to work checks.
b. Administer denied parties, legal due diligence/anti-corruption screening, and quality, occupational health and safety standard checks on vendors, contractors and subcontractors.
Gender
a. Requirements for reporting on diversity and equality.
Government Issued Identification / Passport Number/ National ID
a. Accounting/government tax and auditing business purposes for vendors, contractors and sub-contractors.
b. To run checks for suitability for work for vendors, contractors and sub-contractors.
c. To verify individual’s identity.
Username/Unique Identifier and Password
a. System access and authentication.
b. Administration of safety and protection of LPM systems for recording and monitoring network activity for the purpose of identifying, predicting, and preventing the entry of malicious activity onto or the release of information from LPM network and computing resources.
Medical
a. Required by Occupational Health surveillance laws related to individual’s functional ability and fitness for specific work, with any advised restrictions.
b. To make reasonable adjustments based on disability.
c. Reporting of worksite safety incidents.
Insurance Policy Number
a. Administer quality standard checks on vendors, contractors and sub-contractors.
Bank Information, including Routing and Account Number
a. Remuneration for vendor, contractor or sub-contractor services.
b. Administer denied parties, legal due diligence/anti-corruption screening for vendors, contractors, or sub-contractors.
Job Titles Skills/Work History Experience History Training and Certification Records Evaluations References /Background Check
a. To administer eligibility to work before employment starts.
b. To administer quality, safety and compliance checks and reviews to qualify third party contractors for performing work in accordance with applicable quality standards such as ISO 9001 and NQA-1, including use of individuals who are required to maintain specific qualifications or certifications.
c. Manage LPM business and project-related operations.
Fingerprint scanning, photograph
a. Identification purposes for physical site access and security of certain site locations and project worksites.
Ethnic origin, sexual orientation, health and religion or belief
a. Administer equal opportunities monitoring.
3. How Data is Collected
We use different methods to collect data from and about you:
a. Direct Interactions: You give us your Personal Information when contacting us through candidate profiles, through interviews, or in response to surveys, jobs, projects, bids, through quality and compliance questionnaires, proposals or other means. This includes information you provide when you submit your CV/resume or contact details through our website, email, and via our alumni or talent networks.
b. Third Parties or Publicly Available Sources: Leadenhall may obtain information about you from a representative of your company (if we are sub-contracting services), publicly available online records, background check providers, criminal records check, or past or current professional references you supply to us. The firm will seek information from third parties only once a job offer, or business opportunity has been made and will inform you or your company representative that it is doing so.
We do not undertake automated decision making or profiling on Personal Information or Sensitive Personal Information.
4. Legal Basis for Processing
For Leadenhall to process Personal Information we must have a lawful basis for doing so and at least one of the following must apply:
a. Consent: an individual must give clear consent for us to process their personal information and then only for a specific purpose.
b. Contract: the processing is necessary for a contract that Leadenhall has with an individual, or because we have asked the individual to take specific steps before entering into a contract.
c. Legal Obligation: the processing is necessary for Leadenhall to comply with the law. d. Vital Interests: processing is necessary to protect someone’s life.
e. Public Task: the processing is necessary for Leadenhall to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
f. Legitimate Interests: the processing is necessary for the purposes of the legitimate interests pursued by Leadenhall or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data where the data subject is a child.
Unless otherwise required by applicable data protection law, Leadenhall relies on legitimate interests for processing Personal Information during the recruitment process, forming contractual business relationships, and complying with legal requirements. Where Leadenhall relies on legitimate interests as a reason for processing Personal Information, it has considered whether those interests are overridden by the rights and freedoms of individuals affected by that need.
Leadenhall adheres to the following guidelines to ensure that its collection of Personal Information is fair and lawful. Specifically:
a. Collects only as much Personal Information as is required by law or needed for reasonable and legitimate business purposes.
b. Collects Personal Information in a non-deceptive manner.
c. Where appropriate, informs individuals which Personal Information is required, and which is optional at the time of collection.
d. Collects Personal Information from individuals consistent with local legal requirements.
Leadenhall may need to collect Sensitive Personal Information. Where required under applicable local law, such Personal Information will be processed with consent. Where required by applicable local law, consent to transfers or uses of Sensitive Personal Information will be opt-in.
5. Use and Retention
Leadenhall uses, stores, retains, and otherwise processes Personal Information only for reasonable business purposes and for only as required for that business purpose or as authorized.
Leadenhall does not disclose Personal Information to third parties for direct marketing purposes, nor does it sell Personal Information. Processing of Personal Information will comply with contractual, regulatory, and local legal requirements.
Leadenhall stores and destroys Personal Information based on our data retention policies and procedures. Leadenhall retains the data for as long as it serves the purpose of processing for which it was collected or subsequently authorized.
6. Data Privacy Rights
Where permitted or required by applicable law, Leadenhall extends certain data privacy rights to you.
Note that we may be unable to provide you access to your Personal Information in instances where we have destroyed, erased, or anonymized the data, if we are unable to verify your identity using information we have on file for you, or if it would reveal Personal Information about another person. We may also refuse any request if applicable law allows or requires us to do so. We will inform you of the reasons for refusal.
If you choose to contact us to submit a request, you will need to provide us with:
• Enough information to identify you [(e.g., your full name, address, birthdate, or other identifier)]
• A description of what right you want to exercise and the information to which your request relates. We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or if someone authorized to act on such person’s behalf.
Any Personal Information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
a. The right to request access. You have the right to request Leadenhall for copies of your Personal Information.
b. The right to request rectification. Leadenhall relies on you to ensure the information you provide to Leadenhall about you is accurate, complete and current. If any Personal Information is inaccurate or incomplete, you may request that your Personal Information be corrected or completed. Leadenhall will correct or delete Personal Information as required by applicable law. You may also request to correct, amend, or delete Personal Information that has been processed in violation of applicable data protection law.
c. The right to request erasure. You have the right to request Leadenhall to delete your Personal Information under certain conditions.
d. The right to withdraw consent. Where you have provided written consent (or positive opt-in) to the collection, processing, or transfer of Personal Information, you may have the legal right to withdraw consent. Where we have processed your Personal Information with written consent (or positive opt-in), you can withdraw that consent at any time. Note - withdrawing consent will not affect the lawfulness of any processing we conducted prior to withdrawal, nor will it affect the processing of the Personal Information conducted in reliance on a lawful basis other than consent.
e. The right to request portability. You have the right to request Leadenhall to transfer your Personal Information that we have collected to another organization, or directly to you, under certain conditions.
f. The right to restrict processing. You have the right to request that Leadenhall restrict the processing of your Personal Information, under certain conditions.
g. The right to opt-out of email marketing. You can opt-out of email marketing communications at any time by selecting the email’s “Opt-out” or “Unsubscribe” link, or following the instructions included in each email subscription communication.
h. The right to file a complaint. If you consider that your privacy rights have not been adequately addressed, you have the right to submit a complaint to Leadenhall .
You can submit a request to exercise these data privacy rights to steve.mcconaghy@leadenhallpm.com. Leadenhall will request specific information to help confirm identity and rights.
Leadenhall will not discriminate against individuals for exercising any of their privacy rights allowed or required by applicable data protection law or regulation.
7. Sharing and Onward Transfer
Leadenhall shares Personal Information in the following ways:
a. Affiliates: Leadenhall shares information among Leadenhall affiliates for the purposes described in this Privacy Notice where consistent with applicable legal requirements.
b. Third-Party Suppliers: Leadenhall shares Personal Information to selected affiliated or trusted third party suppliers to perform services on behalf of the organization. These trusted third-parties include, but are not limited to Information Technology Providers, Cloud Providers, Data Hosting Services, Denied and Restricted Party Screening Providers, Background Check Providers, and Data Storage Providers.
c. Clients: Leadenhall shares certain Personal Information as part of our professional services under contract to our clients, including governmental agencies, for project-related work, security clearances or as required by security protocols.
d. Other Third Parties: Leadenhall discloses certain Personal Information to other third parties:
i. where required by law or legal process (e.g., to tax and social security authorities). ii. where Leadenhall determines it is lawful and appropriate.
iii. to protect Leadenhall’s legal rights (e.g., to defend a litigation suit or under a government investigation or inquiry) or to protect its employees, resources, and workplaces; or iv. in an emergency where health or security is at stake.
e. Public Security/Law Enforcement: Leadenhall may be required to disclose Personal Information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
8. Data Security
Leadenhall has adopted and maintains reasonable and appropriate information security policies, processes and/or procedures to safeguard Personal Information from loss, misuse, unauthorized access, disclosure, alteration, destruction, and other Processing. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. As such, we cannot promise, ensure, or warrant the security of any Personal Information that you may provide to us.
Leadenhall’s information security processes provide for the classification of information and the assignment of protection requirements and information security controls based on the classification of information. The safeguards used to protect Personal Information is commensurate with the level of risk involved.
9. Exceptions
Under certain limited or exceptional circumstances, Leadenhall may, as permitted or required by applicable laws and regulations, process Personal Information without providing notice, access or seeking consent. Examples of such circumstances may include investigation of specific allegations of wrongdoing, violation of company policy or criminal activity; protecting employees, the public, or Leadenhall from harm or wrongdoing; cooperating with law enforcement agencies; auditing financial results or compliance activities; responding to court orders, subpoenas or other legally required disclosures; meeting legal or insurance requirements or defending legal claims or interests; satisfying labour laws or agreements or other legal obligations; collecting debts; protecting Leadenhall’s information assets, intellectual property and trade secrets; in emergency situations, when vital interests of the individual, such as life or health, are at stake; with respect to access requests, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy or the privacy interests of others would be jeopardized; and in cases of business necessity.
10. Complaints and Questions
If you feel that your rights have not been adequately addressed, you have the right to submit a complaint to steve.mcconaghy@leadenhallpm.com
11. Terms and Definitions
a. Data Privacy means the legal rights and expectations of individuals to control how their Personal Information is collected and used.
b. Personal Information means any information relating to describing, reasonably capable of being associated with, or capable of reasonably being linked, directly or indirectly, to an identified or identifiable natural person.
c. Processing means any operation or set of operations that is performed upon Personal Information.
d. Sensitive Personal Information has definitions that vary from country to country. For example, European data protection laws treat certain categories of Personal Information as especially sensitive, e.g., biometric, information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information specifying medical or health conditions, or sex life.
12. Change Log
Rev | Change Date | Description of Change | Location of Change
0 01-Jan-2022 Initial Release
1 21-Feb-2025 Second Release