Privacy Policy
Last Updated: January 1, 2025
This Privacy Policy (“Policy”) describes how SiiM (“SiiM,” “we,” “us,” or “our”) collects, uses, discloses, and protects Personal Data in connection with our leadership-development programs, executive assessments, talent-placement evaluations, and related professional services (“Services”).
SiiM is committed to ensuring the confidentiality, integrity, and lawful handling of all Personal Data entrusted to us by client organizations and individual participants.
1. Scope of This Policy
This Policy applies to:
• H.R managers, executives, managers, placement companies and employees who participate in any of the SiiM programs.
• Client organizations and their representatives;
• Users of SiiM websites, digital platforms, and communication channels.
This Policy does not apply to third-party websites, applications, or services that may be linked from our platforms.
2. Definitions
For the purposes of this Policy:
• “Personal Data” means any information relating to an identified or identifiable individual, including but not limited to names, job titles, assessment results, and professional background.
• “Processing” means any operation performed on Personal Data, including collection, storage, analysis, transfer, or deletion.
• “Client Organization” means any corporation, employer, or entity engaging SiiM to provide Services.
3. Categories of Personal Data Collected
SiiM may collect and process the following categories of Personal Data:
a. Identification and Contact Information
• Full name
• Professional title and position
• Business contact details
• Employer name and organizational affiliation
b. Professional and Assessment Information
• Leadership-assessment responses and results
• Behavioral or psychometric indicators
• Executive competency evaluations
• Performance-related data provided by Client Organizations
• Career history relevant to assessment or placement purposes
c. Technical and Usage Information
• IP address, device information, and browser type
• Access logs and interaction data with our digital platforms
• Cookies and related tracking technologies
d. Information Provided by Client Organizations
Any Personal Data supplied to SiiM to facilitate the delivery of Services, such as employee rosters, managerial hierarchies, or role-specific competencies.
4. Purposes of Processing Personal Data
SiiM processes Personal Data solely for legitimate business purposes, including:
• Conducting leadership assessments, talent evaluations, and executive development analyses;
• Preparing assessment reports, insights, and recommendations for Client Organizations;
• Designing and delivering leadership-development programs, coaching sessions, or executive-placement evaluations;
• Communicating with participants and Client Organizations regarding assessments, program schedules, and results;
• Improving the quality, accuracy, and effectiveness of our methodologies and assessment instruments;
• Ensuring the security and proper functioning of SiiM platforms and systems;
• Complying with legal obligations or responding to lawful requests from authorities.
Personal Data will not be used for purposes inconsistent with those described above unless legally permitted or explicitly authorized.
5. Legal Basis for Processing
Depending on jurisdiction and contractual arrangements, SiiM may process Personal Data based on one or more of the following:
• Performance of a contract with a Client Organization or participant;
• Legitimate business interests, including leadership evaluation and talent development;
• Compliance with legal or regulatory obligations;
• Consent of the individual, where required or applicable.
6. Disclosure of Personal Data
SiiM may disclose Personal Data to:
a. Client Organizations
Assessment outcomes, reports, and leadership insights may be shared with the commissioning Client Organization, in accordance with contractual terms and participant notifications.
b. Authorized Service Providers
Third-party vendors who assist in hosting data, processing assessments, providing IT security, or supporting our operational infrastructure.
All such providers are bound by confidentiality and data-protection obligations.
c. Legal and Regulatory Authorities
Where disclosure is necessary to comply with applicable laws, court orders, or governmental requests.
d. Professional Advisors
Legal counsel, auditors, or consultants engaged to support SiiM’s legitimate business and compliance operations.
We do not sell Personal Data.
7. Cross-Border Data Transfers
Personal Data may be transferred to jurisdictions where SiiM or its service providers operate.
In such cases, SiiM ensures that appropriate safeguards—such as contractual clauses, data-transfer agreements, or legally recognized mechanisms—are implemented to protect the data.
8. Data Security
SiiM employs administrative, technical, and physical safeguards designed to protect Personal Data against unauthorized access, alteration, disclosure, or destruction.
While we strive to ensure a high level of security, no method of transmission or storage can be guaranteed to be fully secure.
9. Data Retention
SiiM retains Personal Data only for as long as necessary to fulfil the purposes described in this Policy, comply with legal requirements, or honor contractual obligations.
Upon expiration of the retention period, data is securely deleted or anonymized.
10. Individual Rights
Subject to applicable law, individuals may have the right to:
• Access the Personal Data we hold about them under to the conditions of the agreement;
• Request correction or updating of inaccurate information;
• Request deletion of Personal Data where legally permissible;
• Object to or restrict certain processing activities;
• Request a portable copy of their Personal Data;
• Withdraw consent where processing is based on consent.
SiiM will respond to such requests in accordance with legal requirements and contractual obligations with Client Organizations.
11. Children’s Data
SiiM’s Services are intended for adults in professional employment contexts.
We do not knowingly collect Personal Data from individuals under the age of 18.
12. Amendments to This Policy
SiiM reserves the right to modify or update this Policy at any time.
Material changes will be communicated through our website or directly to affected Client Organizations.
The “Last Updated” date at the top of this Policy reflects the most recent version.
13. Contact Information
For questions, concerns, or requests regarding this Policy or our data-protection practices, please contact:
SiiM – Data Protection Office
Email: info@siim-pro.com