Last updated: 17 May 2018
Previous version: 29 June 2012
This website (the "Website") is operated by Cushman & Wakefield Debenham Tie Leung Limited on behalf of ourselves, our group companies, international partnerships and affiliated organisations ("C&W", "we", "our" or "us").
We recognize that when you choose to provide us with information about yourself, you trust us to act in a responsible manner. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.
This applies to personal information that we collect though the Website or when engaging in our relationship or potential relationship with you (or your organisation) as a supplier, customer or business partner.
Cushman & Wakefield is a leading global real estate services firm with 48,000 employees in more than 70 countries helping occupiers and investors optimize the value of their real estate. Cushman & Wakefield is among the largest commercial real estate services firms providing core services of agency leasing, asset services, capital markets, facility services (C&W Services), global occupier services, investment & asset management (DTZ Investors), project & development services, tenant representation, and valuation & advisory. For more information about us, please see the About Us section of our Website.
Depending on your relationship with C&W, we may collect personal information about you that broadly falls into the following categories:
Website information. You can visit our website without telling us anything about yourself. However, in some situations we may ask you to voluntarily provide us with some personal information. For example, this might be if you are interested in signing up to receive emails from us, or reading some research, or attending an event, or participating in any online forum provided by us from time to time, or if you register for any online account made available by us, or contact us via the Website (in which cases we will collect information such as name, email address, organisation, country, zip code/postal code, job title, telephone number(s), details of your comment or query and username/password). When we do receive your personal information we will treat it securely, lawfully and fairly.
When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws. Specifically, the information we collect automatically may include information like your IP address, device type, cookie ID, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked. Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality, relevance and experience of our Website for our visitors. Some of this information may be collected using cookies and similar tracking technology, including web beacons. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookies Notice.
You may also provide us with information about a health condition to facilitate us making adjustments to ensure accessibility to premises and/or events.
If you provide us with information about another person, you confirm that they have appointed you to act for them, that you have informed them of our identity and the purposes (as set out in this Privacy Notice) for which their information will be processed and that you have obtained any necessary consents to the processing of their personal information. When we first contact them, we may tell them where we got the information from.
We use your personal information for the following purposes (or otherwise described at the point of collection):
We may disclose your personal information to the following categories of recipients:
Further information about our group companies, affiliated entities and the third party service providers that may process your personal information (including their location) can be provided on request by contacting us using the details in the How to contact us heading below.
Under European Union data protection law, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Where we process your sensitive personal information, we do so: (i) in the context of know-your-counterparty checks as required by applicable law; (ii) on the basis that the processing is necessary for reasons of substantial public interest; (iii) on the basis of your explicit consent; or (iv) to establish, exercise or defend legal claims.
You can choose not to provide personal information to us. However, unless otherwise indicated, the information that we request is necessary for the purposes of entering into and performing a contract with you or your organisation and/or providing services to you or your organisation and failure to provide it will impede the contracting process and/or the provision of the relevant services.
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), these interests will normally be: to provide our services to you, respond to your queries, improve our Website(s), undertake marketing, or for the purposes of detecting or preventing illegal activities.
Given the business-to-business context in which we undertake the processing of your personal information, and the safeguards that we take to protect your personal information (including as outlined under the How do we protect your information heading below), our legitimate interests are not outweighed by any prejudice to your individual rights and freedoms. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the How to contact us heading below.
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. We take care to allow access to personal information only to those who require such access to perform their tasks and duties, and to third parties who provide services to us or otherwise have a legitimate purpose for accessing it (see under the Who do we share your personal information with? heading above). Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Privacy Notice and that the security and confidentiality of the information is maintained.
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, our Website servers are located in the United States, and our group companies, affiliated companies and third party service providers operate around the world. This means that when we collect your personal information we may process it in any of these countries. For example, we use a third party customer relationship management platform that entails the processing of personal information in the US.
However, we take steps to safeguard your personal information in accordance with this Privacy Notice. These include, for example, reliance on a third party service provider registration with EU-US Privacy Shield (pursuant to Article 45 of the General Data Protection Regulation). Further details about the protection given to your personal information can be provided upon request by contacting us using the details in the How to contact us heading below.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so. If you are a client or vendor (or a representative of a client or vendor) then the information will be retained for a period of time to allow us to provide our services, to comply with applicable legal, tax or accounting requirements and, if necessary, for the establishment, exercise or defence of legal claims.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
If European data protection laws apply, you have the following rights:
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
We link to other websites. We are not responsible for the content or privacy policies of these websites for the way in which information about their users is treated. In particular, unless expressly stated, we are not agents for these websites or advertisers nor are we authorized to make representations on their behalf. In any event, you should explore the privacy practices of those third parties.
In order to bring you more personalized services, we may ask you to establish one or more passwords to gain access to certain services or sections on our Website. You are solely responsible for the control and use of each password you create and we recommend not reusing an old password and creating a strong one.
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the date displayed at the top of this Privacy Notice.
If you have received an e-mail or e-mails from Cushman & Wakefield that you no longer wish to receive, please contact us at [email protected]. If you otherwise have any questions or concerns about our use of your personal information, please contact us at: [email protected]. If you are in Germany, you can contact C&W's German-based Data Protection Officer (DPO).
The data controller of your personal information is the Cushman & Wakefield group entity (i) with which you or your organisation is engaged as a supplier or customer; (ii) which is considering entering into a relationship with you or your organisation; and/or (iii) with which you are engaged as user of a particular Cushman & Wakefield website.
We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. It is important that you read all of this privacy notice ("Privacy Notice") carefully as it sets out how and why Cushman & Wakefield ("C&W", "we" or "us") handles your personal information when you apply for a job or other role with us and the rights you have in connection with that information. The term "applicants" is used in this Privacy Notice to refer to anyone who applies for a job role, or who otherwise seeks to carry out work with or for us (whether on a permanent or non-permanent basis).
If you have any comments or questions about this Privacy Notice, please contact us using the contact details set out in Section 9 below.
Information that we collect automatically
You can visit the recruitment section of our website ("Website") and search for jobs without providing personal information. However, we do collect certain information automatically from your device when you visit our Website. For further information, please see the privacy notice that applies to the use of our Website.
Personal Information collected from you
Where permitted by, and in accordance with applicable law, the types of personal information we collect and use when you apply for a role and during the recruitment process with C&W includes (but is not limited to):
As a general rule, during the recruitment process, we do not collect or process any of the following: information that reveals your racial or ethnic origin, religious, political or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health/sex life, unless permitted by applicable law or where necessary to comply with applicable law ("Sensitive Personal Information").
In some circumstances, to the extent permitted by, and in accordance with, applicable law, we may need to collect, or request on a voluntary disclosure basis, some Sensitive Personal Information for legitimate recruitment-related purposes: for example, information about your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination or other laws and for government reporting obligations (any reports produced by us in this context would not directly identify you, unless we are legally required to do so); or information about your physical or mental condition to consider accommodations for the recruitment process or at job offer stage for the purposes of making any necessary accommodations for the relevant job role; or information about criminal convictions or offences. You may provide, on a voluntary basis, other Sensitive Personal Information during the recruitment process.
Personal information collected from other sources
We may collect personal information other than directly from you, for example:
(in each case where permissible by, and in accordance with applicable law, including any requirement in relation to obtaining your consent, and, in the case of criminal records checking, use of background checking agencies, and collecting information from publicly available sources, where justified by reference to the job role, in which case you will be provided with further information prior to the checks being carried out).
We collect and use this personal information to manage our recruitment related activities, for organisational planning purposes globally, as well as to comply with applicable laws and regulations. Consequently, we use your personal information to identify and attain new talent, to determine your qualifications and to reach a hiring decision and to generally manage and improve our recruitment and hiring processes. This includes assessing your skills, qualifications and background for a particular role, setting up interviews and tests, verifying your information, carrying our reference checks or background checks (where applicable), generally managing the hiring process and communicating with you about it.
If you are accepted for a role at C&W, the information collected during the recruitment process will also be used to assist with the process of on-boarding (including establishing systems access and preparing for induction), will form part of your ongoing staff member record (where relevant to the ongoing employment relationship).
We take care to allow access to personal information only: (i) to those who require such access to perform their tasks and duties; (ii) to our group companies for processing in accordance with this Privacy Notice; and (iii) in the other circumstances described below in this section. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Privacy Notice and that the security and confidentiality of the information is maintained.
Transfers to other group companies
We will share your personal information with other members of the C&W Group for processing in accordance with the purposes set out in this Privacy Notice.
Transfers to third party service providers
We may make certain personal information available to third parties who provide services relating to the recruitment process to us, including:
Further information about our group companies and about the IT service providers that may process your personal information (and their locations) can be provided on request via the contact details indicated below. These service providers may change over time but we will always seek to ensure that any third parties who handle your personal information will do so in a manner consistent with this Privacy Notice and in accordance with applicable data protection law.
We may also disclose personal information to third parties on other lawful grounds, including:
Where you have provided your consent;
Under European data protection law, our legal basis for processing your personal information as part of the recruitment process is:
You can choose not to provide personal information to us. However, unless otherwise indicated, where we request information from you, it is necessary to comply with a legal requirement or to consider your suitability for an offered job.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.
Personal information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Privacy Notice or as otherwise required by applicable law. We will keep your information for 12 months from the date that you submitted your application (or the latest update of your details by you). Where we undertake vetting for certain positions (where permissible and in accordance with applicable law), we will securely destroy the information obtained by a vetting exercise as soon as possible, or in any case, within 6 months (retaining only a record of the result).
In general, we will not hold recruitment records beyond the statutory period in which a claim arising from the recruitment process may be brought unless there is a clear business reason for exceeding this period.
Under certain circumstances, by law you have the right to:
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact [POSITION] in writing.
Right to withdraw consent
When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact, Alison Williamson, Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
Please address any questions or requests relating to this Privacy Notice to [email protected]. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.