This privacy statement is effective as of 6 August 2019. Please note that this privacy statement will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.
Scope and application
This Privacy Statement explains how Accenture PLC and/or its affiliates, and newly acquired companies, jointly with Associazione Alumni Accenture protect the personal data they process and control about you (“your personal data”), in their quality of joint data controllers, in relation to the Accenture alumni network site (www.accenturealumni.com) hereafter referred to as the "Alumni Site" and AAA site (www.accenturealumni.it) The Alumni Site is administered by Conenza Inc on behalf of Accenture.
Accenture PLC (and/or its affiliates, and newly acquired companies) and Associazione Alumni Accenture (collectively, “Accenture” or “we”) have in place an arrangement setting out their key roles and responsibilities regarding the processing of your personal data and you can obtain a copy of those principles upon simple request using the contact details further mentioned in this notice.
This Privacy Statement in particular explains 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.
The personal data you provide on this site as a user is used by Accenture for the purpose of administering your membership and use of the Alumni Site as a member of the Accenture alumni network, as well as for the purposes set out in the section “For which purposes and on which legal bases do we use your personal data” below. Your personal data will be collected and used in accordance with the terms of this Privacy Statement and applicable data privacy laws.
Your privacy on the Alumni Site
We want you to feel secure when visiting the Alumni Site and are committed to maintaining your privacy online. Please read this Privacy Statement to understand how your personal data will be treated as you use this site. This Privacy Statement may change from time to time so please check back periodically.
The Alumni Site is a private site available only to alumni, former interns and employees of Accenture. Please do not give out your username or password to anyone. If you know of an alumnus looking to get access, please ask them to register at the site. In addition, please respect the privacy of other alumni members and do not give out personal data obtained from the site to anyone.
Please keep in mind that whenever you voluntarily disclose personal data online - in the optional fields in your profile, through email, or in chat areas - those data are accessible to the rest of the alumni community and may be made public. Accenture cannot be responsible for any misuse of such data by others, including any unsolicited messages you may receive as a result of providing data at this site.
You have control over contacts you make on the Alumni Site. My Contacts requires two-way confirmation of requests so that when someone requests to be your contact you must confirm that you want to be their contact. The data that your contacts can access is controlled by your privacy settings. You can select to make data in your profile visible to just your contacts or to all users of the Alumni Site.
Finally, activity feed functionality will be added to the Alumni Site in a future release. Activity feeds highlight activities you take on the Alumni Site such as adding a new contact, submitting a news article, or joining a group. You can select who sees your different types of activities feeds by updating your privacy settings.
Which personal data do we gather?
- Data you provide us when you register. During registration and profile set-up, we require that you provide your name and email address. If you were previously a user of another Accenture alumni website, additional data that you provided to that site may be automatically added to your profile at the Alumni Site. In addition, your user profile offers you the opportunity to provide a wide range of additional data, including postal address, current occupation, industry, education, and personal and business interests. The more data you volunteer (and the more accurate it is), the better we are able to customize your experience. However, please supply only data that are relevant for the stated purposes of this website.
- Correspondence between you and us in relation to the Alumni Site.
- Data you post on the Alumni Site, such as on the chat pages.
- Responses to online surveys that we use for research and quality control purposes.
- IP addresses, which are collected indirectly through our website technology and used for system administration purposes.
- Your personal details.
- Details on (former) compensation and payroll.
- Details on (former) position.
- Birth year.
- Certain sensitive data (as further explained below).
- Personal data we already have in our Accenture system such as (former) Enterprise ID, (former) office location, telephone number, home address and education or training – this to verify your identity when registering on our Alumni Site.
Except for certain data that are required by law, your decision to provide any personal data to us 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 data, we may not be able to accomplish some or all of the purposes outlined in this Privacy Statement, and you may not be able to use the parts of the Alumni Site that require the use of such personal data.
Any public data regarding your professional experience obtained by Accenture may be proactively added to your individual profile. Please see the section below on your rights in relation to your personal data and how to access and correct any data we have about you.
Accenture also shares a small amount of data which we already have in our systems about you with our alumni vendor Conenza during the registration process in order to verify that you are an Accenture alumnus/a. These data include your name, mailing address, last Accenture home office, position and level, (former) Enterprise ID, telephone number, home address and education or training.
Do we transfer your personal data?
As mentioned in the section “With whom does we share your personal data?” below, we may transfer your personal data to Accenture affiliates and certain third parties. Where such affiliates or third parties are located in countries outside of the European Economic Area (including the United States), any such transfers will occur in accordance with this policy and applicable laws. In particular:
- Any transfers of your personal data from offices within the European Economic Area (EEA) to other Accenture offices 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.
- When we transfer your personal data to any third parties, we will make sure that they agree to apply the same levels of protection as we are required to apply to your data and to use your data strictly in accordance with our instructions. 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 firstname.lastname@example.org). Any other, non-EEA originating, international transfer of your personal data will take place in accordance with the appropriate international data transfer mechanisms and safeguards.
For which purposes and on which legal bases do we use your personal data?
To enable other users to search for and locate you via the directory.
Justified on the basis of our legitimate interests of offering users the possibility to use the Alumni Site to contact other alumni.
Primarily, to provide our users with a customized experience on the Alumni Site, including personalization services such as News and Events and interactive communications.
Justified on the basis of our legitimate interests of providing our users with a customized experience.
To research and analyze our users' demographics, interests and behavior in an aggregated form.
Justified on the basis of our legitimate interests to better understand and serve our users and improve the Alumni Site and its offerings.
To contact you periodically with communications about events, publications or employment opportunities with Accenture, which we feel might interest you, unless you ask not to be contacted. You will have an opportunity to opt out of receiving further messages.
Justified on the basis of our legitimate interest for ensuring proper communication with, and sending marketing to, our alumni.
To share with other internal Accenture systems, specifically our internal sales tool (salesforce.com), to contact you with industry relevant information.
Justified on the basis of our legitimate interest for ensuring proper communication with, and sending marketing to, our alumni.
Undertaking data analytics, i.e. applying analytics to your alumni activities (e.g. your attendance to webinars/events) and data to describe, predict and improve our alumni program and/or to provide a better user experience.
Justified on the basis of our legitimate interests for ensuring the proper functioning of our alumni program and to ensure our alumni get the best user experience.
Please note that:
- Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our 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 email@example.com.
- Where any of the above purposes involve an automated decision, we 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.
- We will process your personal data based on your prior consent to the extent such consent is required by mandatory law.
- To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to a privacy statement, doing so will be considered as providing your consent to process your personal data, only in the countries where such consent is required by mandatory law. In all other countries, such action will be considered as a mere acknowledgement and the legal basis of the processing of your personal data will not be your consent but any other applicable legal basis.
We will not use your personal data for purposes that are incompatible with the purposes listed in this 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.
We obtain your personal data either directly from you, or in certain cases from third parties. The third parties from whom we may obtain your personal data are other alumni, our affiliates, public authorities, public websites and social media.
With whom do we share your personal data?
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.
The Alumni Site does not sell or rent your personal data. [If expand is available use this sentence for this section]: In certain cases we may disclose your personal data to third parties. For a complete list of any such third parties, please click here. [“here” expands following info] We will not disclose any of the personal data you provide to this site to third parties, except:
- To our professional advisors, service providers, auditors and contractors, including Conenza, who may help develop or maintain this site.
- When required by law or a court of tribunal of competent jurisdiction.
- To third parties in connection with a corporate / commercial transaction, including in the event that Accenture sells or liquidates all or any part of its business or assets.
- To business partners or sponsors where this is necessary for the purposes related to the Alumni program, in which case this will be specifically described to you prior to data collection or prior to transferring the data, and you can choose not to allow the transfer by not using that particular service.
- To any public or governmental authorities.
- In special cases when this is necessary in order to identify, contact or bring legal action against someone who may be violating our Terms of Service or may be causing injury to or interference with (either intentionally or unintentionally) someone else's rights or property.
- With your prior and informed consent, for any disclosures not mentioned above.
What are your choices and rights in relation to your personal data?
When you register, your name appears in the alumni directory and is visible to other registered members of the Accenture alumni community. When you complete your profile following registration, you may choose which pieces of data are visible in the directory using the "Show" feature. You may change this at any time by editing your profile using the "My Profile" function.
You can choose not to receive any communications from us about events or publications we feel might be of interest to you. However, so long as you are a registered user of the Alumni Site, you may not opt-out of receiving communications related to the administration of your membership - e.g. notifications about changes in service, etc.
Finally, you can ask us to delete or deactivate your user account, but then you will not be able to access any members-only areas of the Alumni Site. If you choose to deactivate your account, we will delete any residual data after a reasonable time, unless otherwise required by law.
In addition to the foregoing, 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 we no longer process 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 we only process 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 us, or request us 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 protection officer at firstname.lastname@example.org. Please note that this will not affect our right to process personal data obtained prior to the withdrawal of your consent, or our 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 protection privacy or other laws and regulations.
You can exercise these rights and choices by contacting us at:
Accenture Limited Dublin
1 Grand Canal Square,
Grand Canal Harbour,
Dublin 2, Ireland.
If, despite our 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 us 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 us 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).
Do we process sensitive personal data?
We do not generally seek to collect sensitive personal data through this site. In the limited cases where we do seek to collect such data, we will do where permitted by applicable law and/or with your prior consent.
The term "sensitive personal data" refers to the various categories of personal data identified by European and other data privacy laws as requiring special treatment. These categories may include personal identity numbers, racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union or profession or trade association, physical or mental health, biometric or genetic data, sexual life, or criminal record (including information about suspected criminal activities).
How long do we retain your personal data?
- We retain your personal data as long as we have an ongoing relationship with you.
- We retain your personal data for as long as needed in order to comply with a legal obligation to which we are subject.
- We retain your personal data where this is advisable to safeguard or improve our 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 us of any material changes to your personal data.
Which security precautions are in place to protect the loss, misuse, or alteration of your personal data?
We maintain organizational, physical and technical security arrangements for all the personal data we hold. We have 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 we undertake.
We adopt market leading security measures to protect your personal data. This includes (without being limitative):
- We hold an ISO27001 certification, which indicates that we adhere 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 our processes and security controls provide an effective framework for protecting our clients’ and our own information.
- We have a global Client Data Protection program in place which governs the stewardship of client information and systems entrusted to us.
- We have regular penetration testing performed by a third party provider, which continues to show the strength of our technical defenses.
Your user account data are password-protected so that only you and Accenture have access to these personal data. Do not divulge your password to anyone. Also remember to sign out of your account and close your browser window when you have finished using the Alumni Site, particularly if you share a computer with someone else or are using a computer in a public place like a library or Internet cafe.
You should understand that the open nature of the Internet is such that information and personal data may flow over networks connecting you to our systems without security measures and may be accessed and used by people other than those for whom the data is intended.
The Alumni Site may, from time to time, contain links to and from the sites of our partner networks, advertisers and affiliates. If you follow a link to any of these sites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for these policies or sites. Please check these policies before you submit any personal data to these sites.
Do we process cookies?
How can you enforce this Privacy Statement?
If you think we are not adhering to the terms of this Privacy Statement, please contact Accenture at dataprivacyofficer@Accenture.com.
How can you contact Accenture?
If you have any further questions on this Privacy Statement or how your personal data is used in relation to the membership services at this site, please contact Accenture’s data privacy officer using the contact information provided below.
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 the this address: Accenture Limited Dublin, 1 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.