Recruitment Privacy Policy

Introduction

This is the Recruitment Privacy Policy of BCG Digital Ventures, an operating division of Boston Consulting Group, Inc. encompassing the companies listed below (“we”, “BCGDV”).

This Privacy Policy only applies to the personal information of job applicants and potential candidates for employment, and our optional recruiting programs, newsletters and events.

The purpose of this Recruitment Privacy Policy is to inform you about how we process your data for recruiting purposes and to explain the rights you have in relation to your personal data.

Our career site may contain links to external sites which are not governed by this Privacy Policy. BCG Digital Ventures does not take responsibility for the privacy practices of any third-party sites to which we link. We encourage you to review the privacy policies of any such sites before you submit information there.

Who is responsible for processing your personal data, how can you contact the Data Protection Officer?

For individuals applying to BCG Digital Ventures or one of our portfolio ventures, the BCG Digital Ventures center that you apply to, or that is listed in a job advertisement is responsible for the processing of your personal data.

If you apply for a job at/via:	The responsible data controller is:
BCGDV UK	BCG Ltd, 20 Manchester Square, London W1U 3PZ
BCGDV Germany	BCG Digital Ventures GmbH, Dircksenstrasse 41, 10178 Berlin
BCGDV Singapore	BCG Pte Ltd 50 Raffles Place, #44-02/03 Singapore Land Tower, Singapore 048623
BCGDV USA	BCG Inc, One Beacon Street, Boston, MA 02108
BCGDV China	BCG Digital Ventures, an operating division of Boston Consulting (Shanghai) Company Limited, 696 Weihai Road Jing’an District, Shanghai 200011
BCGDV Japan	The Boston Consulting Group, Inc Nihonbashi Muromachi Mitsui Tower 25F, 3-2-1 Nihonbashi-Muromachi, Chuo-ku, Tokyo 103-0022
BCGDV Australia	BCG Digital Ventures, Pty Ltd, 1/80 George Street, The Rocks, Sydney, NSW 2000
BCGDV KSA	BCG Digital Ventures, an operating division of The Boston Consulting Group International Inc – Riyadh Branch, 11th Floor, Tower A, Olaya Towers, Riyadh 12213
BCGDV UAE	BCG Digital Ventures, an operating division of The Boston Consulting Group International Inc, The Offices 3 at One Central Dubai, Level 7, P.O. Box 32257, Dubai
BCGDV India	BCG Digital Ventures, an operating division of The Boston Consulting Group (India) Private Limited, 14th Floor, Nariman Bhavan, 227, Nariman Point, Mumbai 400 021
BCGDV Brasil	BCG Digital Ventures, an operating division of The Boston Consulting Group (Brasil) Ltda, Rua Surubim, 373 – 30. andar, Sao Paulo, SP 04571-050
BCGDV Morocco	BCG Digital Ventures, an operating division of The Boston Consulting Group SARLAU, 104 Boulevard Abdellatif Ben Kaddour, Casablanca 20050

You can reach our Data Protection Officer under: dataprotection (at) bcgdv.com.

What personal data do we collect from you?

When you actively apply for employment at BCG Digital Ventures, or our portfolio ventures, you will be asked to submit your contact details and your resume/CV containing information that you deem relevant for the process, such as educational and employment history.
We also require information on your visa and/or immigration status regarding employment at the location you are applying for.
Temporarily – your affiliation with the Ukraine – This information will allow us to consider waiving local language requirements for suitable roles, where you meet all other hiring requirements.
In addition to the data you submit directly to us, we may also collect information from third-party sources, such as professionally-focused social networks or public sites.
When you enter the interview stage, we collect details from your interviews, such as further information on your experiences and your salary expectations, as well as the outcome of “take home” challenges, if applicable.
With your consent, we also collect information from reference persons you list.
We may also carry out background checks, including criminal records, where legally permissible.
If you sign up for our recruiting newsletter, we ask you for your email address. For further information on our newsletter, see here.
We collect your sensitive personal information, such as racial or ethnic origin identities and disabilities, only with your consent and where we are permitted to do so by applicable laws (e.g. US equal opportunity monitoring).
Information that enables us to book travel for you (e.g. passport or ID number, travel preferences dietary requirements) or reimburse you for travel costs (e.g. travel and bank account details), in case of onsite interviews.
Active sourcing: BCG Digital Ventures also conducts active sourcing to identify promising talents in the labor market. This means, we collect personal data such as name, contact data, employment history and current position of potential applicants from professional social networks, public sites or referrals from our employees. The purpose of the data collection is to analyze if you might fit a vacancy and to actively initiate contact with you. In all cases, we will notify you that we have collected your data for the purpose of active sourcing.

Please note that the provision of personal information is neither a statutory nor a contractual requirement, nor are you obliged to provide such information. However, failing to do so may result in BCG Digital Ventures not being able to progress your candidacy for the position that you have applied to.

How do we use your information?

We use your personal information in the context of the recruitment process:

To evaluate your suitability for the immediate role you have applied for and conduct the interviewing process.
In case of active sourcing, to analyze if you may fit a vacancy and to actively initiate contact with you.
On an aggregated basis, for analytical and statistical purposes, to understand and improve our recruiting processes.
On the basis of your consent, to add you to our talent pool for the purpose of considering your profile for other upcoming roles at BCG Digital Ventures and our portfolio ventures. Giving your consent is voluntary and you may withdraw it at any point.
However, withdrawal of consent will not affect the lawfulness of processing prior to withdrawal.
If the recruitment process leads to employment: to process personal information collected during the recruitment process for the purposes of entering into an employment contract or fulfilling our related legal obligations. Thereafter, the processing of your personal data will be governed by our internal data processing policies, of which you will be informed when starting your new job.
To ensure compliance with legal requirements, including diversity requirements and practices (where required by applicable laws).
US only: if you voluntarily participate in our demography survey, we will use your aggregated sensitive information to help us identify areas for improvement within our diversity efforts. If you choose to respond, your information will be stored separately from your application, and will not be associated with your specific application at any time.
If you are invited to onsite interviews, to book travel for you or reimburse your travel costs, if applicable.
To safeguard our legitimate interests, including defending ourselves against any legal claims arising from the recruitment process.

When will we share your information?

BCG Digital Ventures is part of the BCG group of companies and we may need to share your personal information with other BCG subsidiaries and affiliates insofar its required for the purposes detailed above. Additionally, your personal information will be processed by our contracted third-party service providers for services such as data hosting and the recruiting software platform.

If you apply for a position in one of our portfolio ventures, we may need to share your application data with the portfolio venture in question, as well as our corporate partner with whom we collaborate on this particular venture.

Similarly, if you consent to your data being added to our talent pool, we may share your application data with our portfolio ventures and the corporate partners, with whom we collaborate in building these ventures. We may also share your information with law enforcement bodies in order to comply with any legal obligation or court order.

Where do we store your data?

Your personal data will be stored within our applicant tracking system provided by Greenhouse Software Inc, 18 W 18th Street, 9th Floor, New York, NY 10011. This involves your personal information being stored and processed outside of the European Economic Area (EEA) in the United States. While privacy laws in third countries differ from those in the EEA, we only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect information held in that country. We have entered into EU Standard Contractual Clauses with our third-party service providers, that require the recipients of the data to abide by data protection rules approved by the European Commission. Please contact us if you wish to request a copy of the specific safeguards applied to the transfer of your personal information.

How do we protect your information?

BCG Digital Ventures has in place appropriate technological and operational security processes designed to protect your personal information from loss, misuse, alteration or destruction. Only authorized employees and providers will have access to any data provided by you, and that access is limited by need. Each employee or provider that has access to any personal information is obligated to maintain its confidentiality. Although we take steps that are generally accepted as industry standard to protect your personal information, BCG Digital Ventures cannot guarantee that your personally-identifiable information will not become accessible to unauthorized persons and BCG Digital Ventures cannot be responsible for any actions resulting from a breach of security when information is supplied over the internet or any public computer network.

How long will we retain your information?

In the case that your application is not successful, we may continue to retain and use your personal information for a period of time (which may vary depending on the country), for system administration purposes, to perform research and to defend our legal interest. At the expiry of this period, we may retain a minimum amount of your personal information to record your recruiting activity with us. Otherwise your personal data will be anonymized.
If we have actively sourced your information (see above: active sourcing), we will retain it only as long as necessary to assess whether we have a suitable position for you. This time frame will not exceed six months; however, this is extended if you decide to actively enter our recruiting process.
If you have given your consent to being added to our talent pool, we will store your personal information for up to 3 years in order to consider your profile for future opportunities. If you wish to withdraw your consent, please contact us.

What legal basis do we have for processing your information?

BCG Digital Ventures is a global company, so the legal basis for the processing of your personal data depends on which BCG Digital Ventures entity is processing your data, and for what purpose we are processing it. In general, we see our recruiting activities to be in our legitimate interest, as it helps us to find the best employees for our company and portfolio ventures, or we ask you to consent.
In cases where European or German law applies to our recruiting processes, the legal basis for our processing activities is as follows:

Handling active applications	Art. 6 para. 1 lit. b of the EU General Data Protection Regulation (GDPR), taking steps prior entering into a contract Art. 88 para. 1 GDPR in connection with § 26 para. 1 German FDPA, where German law applies
Processing travel cost reimbursement	Art. 6 para. 1 lit. c GDPR complying with legal obligations such as accounting and tax regulations
Retention of data in case of rejection	Art. 6 para. 1 lit. f GDPR, our legitimate interest results from defending us against possible lawsuits and protecting ourselves against fraudulent applications
Active sourcing Analyzing recruiting process	Art. 6 para. 1 lit. f GDPR, our legitimate interest results from our constant search for the best employees, approach to constantly improving our recruiting process
Joining the talent pool References Sensitive personal data you might disclose	Your consent – Art. 6 para. 1 lit. a, 9 para. 2 lit. a GDPR

Your rights

In accordance with applicable data protection laws, including but not limited to the GDPR and the California Consumer Privacy Act (CCPA), you have a right to request a copy of the personal information we hold about you and details of how we use that information.

If any of the information held about you is incorrect or out of date, you have the right to amend or rectify it. Please follow the process outlined below and we will amend our records where appropriate.
You also have the right to require us to erase your personal data, stop processing your personal data, restricting the processing of your personal information, right of portability of your personal information and/or to withdraw your consent to processing. This may not apply if there are other legal justifications to continue processing. If you wish to exercise any of these rights, please contact us.
In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information deleted or otherwise let us know what limitations you would like to put on our use of your personal information. For your protection, we may need to verify your identity before implementing your request.
In addition to the above rights, you also have the right to lodge a complaint with your local data protection authority.

How to make a complaint?

You can complain to us in writing about how we have handled your personal data. We will respond to the complaint within 30 days.

How to contact us?

For further questions, you may contact the appropriate data protection point of contact:

Data Protection Office
The Boston Consulting Group Inc.
One Beacon Street
Boston, MA 02108
dataprotectionoffice (at) bcg.com

California
California residents may exercise their privacy rights by calling us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and entering service code 837# to leave us a message.

BCG Digital Ventures GmbH
Dircksenstrasse 41
10178 Berlin, Germany
dataprotection (at) bcgdv.com

Updates to this Policy

We reserve the right to amend this Privacy Policy from time to time without further notice. Previous versions of this Recruiting Privacy Policy are available upon request.

Last updated: August 2022