CANDIDATE PRIVACY NOTICE

Latest update: June 2026

Welcome to Badenoch + Clark! We look forward to working with you to help you further develop your career.

This Privacy Notice (“Privacy Notice”) describes what personal information we collect from you, how we collect, use and process it, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights. We know it is long, but please read this Privacy Notice carefully.

1. Some terms to be clear about

In this Privacy Notice, you will be referred to as ‘the Candidate’ or ‘You’.

When we talk about ‘us’ or the ‘Company’, we mean Badenoch and Clark, Badenoch + Clark, (B+C), operated by Adecco Professional Staffing NV, with registered address at Noordkustlaan 16b, 1702 Dilbeek, Belgium. The Company is part of the Adecco Group AG (Adecco Group), with its headquarters at Bellerivestrasse 30, 8008 Zurich, Switzerland. It is the largest HR services provider in the world. Through its various companies and business lines, the Adecco Group provides several HR (Human Resources) activities such as staffing, secondment, payroll services, recruitment and selection, testing solutions, career transition, talent development, training and education, outplacement, and international mobility (‘our Activities’). 

To carry out our Activities, the Company uses several IT systems. In some cases, the Company provides a Self-Service Portal (‘Portal’) for its candidates and personnel. The Portal allows you to search and apply for jobs the Company and its sister companies advertise which match your interests, skills and/or experience, in the locations where you have expressed an interest in working.

This Privacy Notice is about how we process your information as an individual. It is not about how we process information about companies (although sometimes the two overlap). This type of information is sometimes called ‘personal information’, ‘personally identifiable information’ or ‘PII’. We use the term ‘personal information’ or ‘data’ in this Privacy Notice. 

2. What personal information does the Company collect and use?

We collect and use personal information to provide the best possible employment opportunities tailored to you. We have grouped these as follows:

a) Identity Data means your name, username, title, place of birth and documents evidencing your identity.
b) Contact Data means your address, email address and telephone number.
c) Qualifications and Working Experience Data means any information on your CV, resume or cover letter, including the details of your education, training courses, internships, documents evidencing your right to work, photos and videos as part of the application process, and any relevant information for your application.
d) Social Media Data means your profile data on social media such as LinkedIn and other information you make public on or otherwise share with us from social media.
e) Technical Data means internet protocol (IP) addresses from which you access the Portal and our products and services, cookies, your login data (such as the time, date and duration), the browser type and version you use, time zone settings of your device and your device location, the browser plug-in types and versions you use, the operating system and platform type of the device you use, and other technology on the devices you use to access the Portal, our apps, websites, products and services.
f) Phone Call Data includes the number you used to call us, the time, date and duration of that contact.
g) Profile Data means your username and password, your interests, preferences, feedback and survey responses.
h) Marketing Communications Data means information about how you respond to email, SMS, phone calls and other marketing campaigns.
i) Visitor Information means information we may collect when you access our buildings, such as your name, contact details, other identifying information for security purposes, including CCTV images and door-entry systems logs.
j) Sensitive Data means, as applicable, details of any disabilities and any accommodations we may need to make for you in the workplace, as well as diversity-related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sex life and sexual orientation), or health data (such as sickness records, disability records, fitness for work and health insurance information where it contains data relating to sickness), data about alleged or proven criminal offences, in each case where required or permitted by, and in compliance with, applicable law.
k) Conversational Data means the recording and transcription of the conversation (speech to text) and any summaries.
l) Screening Data refers to checks conducted to verify sanctions lists provided by governmental institutions, such as the European Commission, to ensure that you are not subject to sanctions. In this context, we may also process your Identity Data, such as your name, surname, and date of birth. The information obtained during a screening check is used solely to fulfil our compliance obligations.
m) Background Data means background checks with your professional contacts (e.g., former employers) to verify the accuracy of the experience listed on your resume and to check the various skills highlighted. The information requested during a reference check relates solely to professional skills.

Depending on the relevant circumstances and applicable local laws and requirements, we may collect some of the information listed above to enable us to offer you employment opportunities which are tailored to your circumstances and your interests.

3. Why do we process your personal information and how long do we keep it for?

Purposes of the processing	Type of data	Legal basis to process your personal information	Retention period
To provide you with our services by finding suitable jobs/assignments for you to apply to, helping you with training, or facilitating the process of applying for jobs/assignments. This includes sending your CV to prospective employers for their consideration and keeping you informed of future work opportunities by email, telephone, post and/or other communication methods. It also includes assessing your application and conducting interviews.	a) Identity Data b) Contact Data c) Qualifications and Working Experience Data d) Social Media Data g) Profile Data	Performance of a contract or taking steps prior to entering into a contract	Up to 3 years from your last activity (last job application, interview, phone call or assessment) in the Portal.
To make any adjustments that you may need in the workplace.	a) Identity Data i) Sensitive Data	- Performance of a contract; - Compliance with legal obligations	Within 6 months of your last activity (last job application, interview, phone call or assessment) in the Portal.
To send you direct marketing, for example, via email, messages or telephone, and to administer communications and other systems used by the Adecco Group (including internal contact databases).	a) Identity Data b) Contact Data e) Technical Data f) Phone Call Data h) Marketing Communications Data	- Consent - Legitimate interests to ensure that our systems are functioning properly	For as long as you have opted in to receive our marketing.
To troubleshoot technical call problems on our networks.	a) Identity Data b) Contact Data e) Technical Data f) Phone Call Data	Legitimate interests to deal with technical issues affecting our business	Up to 6 months after the issue has been fixed.
To perform studies, statistical and analytical research, and to further develop, test and improve our website/Portal, or other existing or new systems/processes to better serve you.	e) Technical Data g) Profile Data h) Marketing Communications Data	Legitimate interests to improve and develop our business and improve our systems	Up to 3 years from your last activity (last job application, interview, phone call or assessment) in the Portal.
To transfer data to third parties including Members of The Adecco Group, in accordance with section 7 below.	Any category of data listed above, as necessary	- Legitimate interests to provide services - Performance of a contract - Consent	Up to 3 years from your last activity (last job application, interview, phone call or assessment) in the Portal and any additional period required under applicable local legal obligations.
To comply with our legal obligations, Group Policies and procedures, and investigate or respond to incidents and complaints.	Any category of data listed above, as necessary	Compliance with legal obligations such as keeping records for tax purposes, labour law or providing information to a public body or law enforcement agency.	Up to 10 years from your last activity (last job application, interview, phone call or assessment) in the Portal and any additional period required under applicable local legal obligations.
To ensure security.	a) Identity Data e) Technical Data i) Sensitive Data	Legitimate interests to ensure that our business and the people who work in it are kept secure and safe	Up to 72 hours from your last visit to our premises.
To transcribe the oral conversation between a recruiter and the Candidate and generate a summary.	k) Conversational Data	- Legitimate interests to provide improved services - Performance of a contract - Consent	Up to 1 year from the conversation
To record the written or oral conversation between a recruiter or an AI agent and the Candidate.	k) Conversational Data	- Consent - Performance of a contract	Up to 1 year from the last activity

4. How do we collect your personal information?

The personal information we collect about you comes from the application forms, the transcribed conversations we or our chatbots have with you, or other materials you submit to us, and your interactions with us and others as part of your application.

In some cases, we will also collect personal information indirectly from third parties, such as from recruitment agencies that we work with, other entities in the Adecco Group if you transferred to us from that Adecco Group entity, background check providers, or from publicly available sources such as LinkedIn and X (Twitter) in accordance with applicable law.

5. Do you have to give us the personal information we ask for?

You are not obliged to provide your personal information to us, but it would not be possible for us to work with you, or provide our services to you, if you do not provide us with the minimum required in order to assess your suitability for a position with us. It may also limit the Services that you can receive from us if you choose to provide us with limited personal information.

6. Do we use artificial intelligence?

As part of our commitment to delivering innovative and efficient solutions, we utilize machine learning and deep learning artificial intelligence (AI) technologies, such as generative AI, in our relationship with Candidates. These technologies enable us to digitize, automate and enhance a wide range of processes associated with staff recruitment. For example, we use AI Agents, such as chatbots, to optimize your experience and to make ourselves available to you around the clock. The conversations you have with our AI Agent chatbots provide us with valuable insights that are not immediately evident from your application, profile, or resume, and to quickly determine whether your skills align with the essential requirements of a position.

Third party management

In most cases, we use AI solutions or Large Language Models such as Llama and GPT provided by third parties, such as Microsoft, Google or OpenAI. In order to ensure the security, confidentiality, and proper handling of information, we carefully assess such providers prior to their selection, verifying that they comply with applicable legal, ethical and security standards to protect your personal data. Likewise, we enter into specific contractual clauses regarding liability, aimed at protecting your personal data and data rights and ensuring compliance with current AI, data protection and consumer regulations.

Responsibility Commitment

Our Company is committed to responsible use of innovative HR technologies. Read our Responsible AI Principles here. We do not use these technologies as a substitute for people or for human interaction at any stage of our processes. Our use of these technologies is intended to facilitate interactions with our candidates in a manner that is more convenient and efficient.

While we do use AI systems, all decisions that may affect you are made by our trained recruiters. If, in exceptional cases, we were to make such decisions based on a fully automated process (that is, without human involvement), we would only do so where permitted by law and after notifying you in advance.

Security measures

We take measures to prevent bias in the use of these technologies and ensure that all users are treated fairly. For example:

a) Human Oversight: We review the AI systems before, during and after the go-live date to ensure they operate fairly and effectively. Any anomalies or biases identified are promptly addressed to maintain the integrity of our processes.
b) Testing: All AI systems used are subject to regular testing and audits to minimize bias and ensure fairness. We commit to complying with anti-discrimination laws and implementing technical and organizational measures to mitigate risks of unfair treatment or bias.
c) Data & Quality Management: Our data scientists apply consistent data controls and guardrails to ensure that our data sets are clean and consistent from the outset and monitored throughout the lifecycle of our AI systems.
d) Security: We apply state-of-the-art security controls to our data storage and AI systems to prevent unauthorized access to or tampering with our data sets.

In any instance where you receive a service that involves the use of artificial intelligence, you will be provided with a separate transparency notice detailing information about the algorithm and its use.

Do we use Chatbots?

Yes, we do. We may have engaging conversations with you via our chatbots. Our chatbots are generative AI powered.

In most cases, we will run a three-party model. This means, we will use a large language model (LLM) of a third party and get support from our trusted partners Microsoft or Salesforce to build a safe trust layer between our secured Adecco Group network and the third parties LLM. In our case, the LLM will come from OpenAI. By doing so, we ensure that your personal data remains on our Adecco Group instance and does not get shared with any LLM provider.

Here’s how it works:

You produce a prompt (set of instructions) via inputting a question or other data to our chatbot. This question gets filter via a trust layer before it leaves the Adecco Group environment to enter a LLM. In the trust layer, the data gets masked, personal data and data with sensitive content gets detected and removed before it leaves the Adecco Group network. It gets replaced through specific placeholders. Only then your prompt is sent to the LLM. The LLM responds and sends the answer back to our trusted partners. It does not store any of the masked data, as it has committed to a zero retention period with us and our trusted partners. This means, your personal data is not retained by any LLM we use. Before you receive the answer, the data gets demasked by our trusted partners and only then sent to you.

Will my personal data be used for LLM model training or product improvements by third-party LLMs?

No. Your personal and non-personal data is not used for LLM model training or product improvements by third-party LLMs. Also, no data is retained by the third party LLM. It forgets the masked data once it sends the response back to us. Before we send the response back to you, our trusted partners scan the response for toxicity, and the masked data gets demasked. No human being at the third-party provider looks at data sent to their LLM.

The models use three primary sources of information to provide you with a suitable answer: 1) information that is publicly available on the internet (no information that is behind paywalls or registration platforms), (2) information that we partner with third parties to access, and (3) information that our users or trainers provide or generate.

Is the chatbots output (answer) always correct?

As the model is trained on data from various sources, it may provide you with two completely different answers to the same questions. Also, if its answer is completely wrong, it will tell you with confidence that it is right. Therefore, beware that models hallucinate.

This is because models generate responses by reading your request and, in response, predicting the words most likely to appear next. In some cases, the words most likely to appear next may not be the most factually accurate. For this reason, you should not rely on the factual accuracy of output from our models. If you notice that an output contains factually inaccurate information about you and you would like to request a correction or removal of the information, you can submit these requests through the appropriate contact channels (cf infra).

Be aware, that we have a prompt defence in place. This means, that we protect your personal data through system policies to limit hallucinations and to decrease the likelihood of unintended or harmful outputs by the LLM.

Are we compliant with privacy law by using LLMs?

Yes, as we implement the aforementioned technical measure to keep your personal data safe.

What additional safeguards are in place?

Through our trusted partners we make sure, that harmful data gets scored to improve. The so-called toxicity scores are logged and stored. We also use feedback to improve, and we use dashboards to analyse and to provide a safer and more accurate outcome for you. We check the training data against bias and make sure the chatbot does not discriminate any person for gender, age, ethnicity, religious beliefs, sexual orientation and other privacy right related domains. Also, our processes make sure, that a human is in the centre of our operations and that there is no impactful decision making without human intervention.

7. Do we transfer your personal information to third parties?

To facilitate our efficient use of your information and to provide you with the content, resources and services, we disclose your information to third parties. We do this in the following circumstances:

• To our suppliers. We will, for example, engage suppliers to carry out administrative and operational work, IT suppliers to host or support our IT systems, IT technology services and solutions that provide video interview and skills assessment tools, premises management companies to look after physical security at our buildings, and back-office finance and accounting management providers in order to process accounts payable and receivable.
  The suppliers will be subject to contractual and other legal obligations to preserve the confidentiality of your data and to respect your privacy and will only have access to the data they need to perform their functions.
• To members of The Adecco Group and their affiliates (“Members of The Adecco Group”) within or outside the European Union. A list of the countries in which we operate is available on our website at www.adeccogroup.com/worldwide-locations. Your information will be shared with them for different reasons:
  • with Members of The Adecco Group that provide IT functions for The Adecco Group companies worldwide, for our legitimate interests;
  • with Members of The Adecco Group worldwide (including legal entities acquired after the collection of your information) for the purposes previously described or to propose offers to you adapted to your profile, where you have consented to global data sharing within The Adecco Group to provide you with local or international opportunities in that market;
  • with Members of The Adecco Group worldwide for administrative purposes.
• To our clients/prospective employers. We will share your data with clients of ours who are offering jobs/assignments you may be interested in, or who are interested in your profile, based on the performance of our contract or prior to entering into a contract. They owe us, and you, contractual and other confidentiality obligations in relation to your data.
• To government or law enforcement authorities. We will share your data with government, police, regulators or law enforcement authorities if, at our sole discretion, we consider that we are legally obliged or authorised to do so, or if it would be prudent to do so.
• To prospective sellers or buyers and their advisors. As part of due diligence relating to (or implementation of) a merger, acquisition or other business transaction, we may need to disclose your data to the prospective seller or buyer and their advisors based on our legitimate interests.

8. Do we transfer your personal information outside your country?

Your personal information can be transferred and processed in one or more other countries, in or outside your country. A full list of the countries in which we operate is available on our website at http://www.adeccogroup.com/worldwide-locations.

If we share personal information outside your country, we ensure that we conduct a transfer risk assessment and put in place appropriate safeguards (such as signing the EU Standard Contractual Clauses or the UK International Data Transfer Agreement) to ensure a high level of data protection in the country to which we transfer your personal information.

9. What are your rights regarding your personal information?

Under applicable data protection laws, you have the following rights:

• Right to access your personal information
  You are entitled to request confirmation of whether we process any of your personal information. Where this is the case, you have the right to access your personal information. In some cases, you can ask us to provide you with an electronic copy of your information.
• Right to data portability
  In some circumstances, you have the right to receive the personal data that you have provided to us in a structured, commonly used, and machine-readable format. You also have the right to transmit those data to a third party.
• Right to correct your personal information
  If you can demonstrate that personal information we hold about you is not correct, you can request that this information is updated or otherwise corrected. We would encourage you to access the self-service Portal where possible and update your personal information directly.
• Right to be forgotten or to delete personal information
  In certain circumstances, you have the right to request that your personal information is deleted. This right is subject to any legal rights or obligations where we need to retain data. For situations where, in accordance with the law, we determine that your request to have your personal information deleted must be granted, we will do so without undue delay. Please bear in mind that once your data is deleted, we might no longer be able to serve you. If you want to register with us again, you will need to re-enter your data.
• Right to restrict or object to the processing of your personal information
  In certain circumstances, you have the right to obtain restriction of the processing of your personal information, or to object to certain processing thereof on grounds relating to your particular situation. 
• Right to withdraw consent
  You have the right to withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you want to exercise any of your rights, please use our form by clicking here.

Finally, you also have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your personal information has arisen. However, we encourage you to contact us first so that we can address your concerns directly and seek to resolve any issues you may have.

10. How do we handle changes to this Privacy Notice?

The terms of this Privacy Notice may change from time to time to reflect changes in our practices, legal requirements or for other operational reasons. If the changes are significant, we will provide appropriate notices either on our Portal and/or website or by contacting you using other communication channels.

11. Contact

If you have any questions or concerns regarding this Privacy Notice, or you want to contact The Adecco Group’s Data Protection Officer (DPO) or the local Privacy Lead, please email The Adecco Group’s DPO at globalprivacy@adeccogroup.com or the local Privacy Lead at privacy@adecco.be.

To exercise any of your rights related to your personal information, please fill in this form.