This Data Protection Notice (“Notice”) describes the Personal Information that the Graduate Management Admissions Council, PO Box 2969, Reston, VA, 20195, United States (“GMAC”) and SHL Group Limited of The Pavilion,1 Atwell Place, Thames Ditton, Surrey KT7 0NE, England, (“SHL”) collect as part of the Soft Skills Assessment (the “Assessment”), and how GMAC and SHL use and disclose that Personal Information.
As used in this Notice, the term “Personal Information” means information that relates to you and that identifies or can be used to identify you. Personal Information does not include information that has been rendered anonymous such that it no longer identifies or can be used to identify you.
As described in Section 3 below, GMAC acts as the data controller with respect to Personal Information collected in connection with the Assessment, and SHL administers the Assessment and acts as a data processor on GMAC’s behalf.
As described in Section 4 below, SHL acts as a data controller with respect to the use of certain Personal Information to operate its online assessment platform and to create anonymous and aggregated information that is used to improve SHL’s products and services and conduct statistical research.
This notice applies only to Personal Information collected in connection with the Assessment. This Notice does not apply to Personal Information collected through other GMAC or SHL services or offerings.
This Notice also does not apply to any collection or use of Personal Information by any graduate school or other institution (each a “School”) with whom you direct GMAC to share your Personal Information. If you have questions about any School’s use of your Personal Information, you should contact the School directly.
When you register for and take the Assessment, SHL and GMAC will receive several different categories of Personal Information, each of which are described below.
personal and contact details collected directly from you, and that may include the following:
Additionally, you will be asked optional demographic questions in a survey after the Assessment.The demographic data collected through the survey may be considered sensitive and be classified as a special category of personal information under applicable data protection law. Accordingly, if you chose to answer, you will be required to provide us with your consent to process this information. Providing this information is completely voluntary. If you do not want to answer a question, simply select the "Prefer not to answer" option. If you choose not to answer these questions, it will not prevent you from taking the Assessment or affect the Assessment results in any way.
technical information that is automatically collected through the online Assessment platform and/or that you provide when seeking support for your use of the platform, including browser types, operating system, other device information, IP addresses, and Date / time stamps; and (ii) Personal Information that SHL collects through online candidate help forms, which is required to support candidates requiring assistance.
your answers to the Assessment questions, which are collected directly from you when you take the Assessment.
data generated from the Assessment that reflect your performance on the Assessment, which are based on the Candidate Data and the Assessment Data. Results Data will include inferences about you based on your performance on the Assessment.
Solely to the extent that a School engages with GMAC for validation work, GMAC will receive Personal Information from any School in which you have enrolled. This information may include any of the following:
GMAC will act as a data controller and use your Personal Information for the purposes set out below.
GMAC as the data controller and SHL as its data processor, will use your Candidate Data and your Assessment Data to process your registration for the Assessment, to administer the Assessment and to create your Results Data, and to provide your Results Data to the Schools that you select. Your payment will be processed by an independent third party and all terms with respect to such processing are included as part of the payment process between you and the payment company.
GMAC and SHL perform this processing for the purpose of entering into and performing the agreement between you and GMAC regarding the Assessment. If you fail to provide Candidate Data or Assessment Data, GMAC and SHL may be unable to administer the Assessment and to generate Results Data that can be provided to Schools on your behalf.
GMAC will use your Candidate Data, Results Data, and School-Provided Data to create anonymous data that no longer identifies you or can be used to identify you (such anonymous data, “Research Data”). Research Data does not constitute or include Personal Information.
Research Data may be used by GMAC for its own internal statistical research and to develop and improve its products and services, including by creating aggregate benchmark measurements to evaluate the performance of different groups, programs, and industries.
GMAC undertakes this processing to pursue its legitimate interests in developing and improving its products and services and conducting statistical research.
GMAC will use your Candidate Data, Assessment Data, Results Data, and School-Provided Data, as well as Research Data, to validate the Assessment and its effectiveness in determining competencies for success within graduate management programs, and to ensure that the Assessment fairly and objectively evaluates those competencies.
GMAC perform this processing to pursue GMAC’s legitimate interest in ensuring the validity of the Assessment, and as part of the validation services that GMAC provides to Schools that use the Assessment and Results Data as part of their application and admissions processes.
GMAC and SHL may use your Personal Information to detect and prevent fraud, to confirm authorized users, to resolve disputes, and to enforce our agreements. SHL and GMAC may also process your Personal Information as necessary to comply with legal or regulatory requirements, to respond to requests from a law enforcement or other regulatory authority, or otherwise to protect our rights and property or to prosecute or defend legal claims.
When you complete an Assessment SHL will collect Personal Information about you for the purposes outlined below. SHL will be data controller in respect of this information and we will be responsible for your Personal Information including for what purposes your information is collected and used.
If you have any questions on the processing of your data by SHL as data controller you can contact the SHL Data Protection Officer (DPO) on email@example.com or the contact details included at the end of this Notice.
SHL collects information that you or GMAC give us when you complete an Assessment: including your Candidate Data, Assessment Data, and your Results Data and your School Provided Data (if provided by GMAC).
We also collect Technical Information relating to the systems you used to take the Assessment including:
SHL will anonymise a combination of your Candidate Data, Assessment Data, Results Data, School Provided Data (if any) to create “SHL Research Data” for our own purposes provided below. Once anonymised we use this data to:
We use your Technical and Support Data to primarily provide you with service support and for our own purposes including to identify issues with the assessment platform and your experience of it.
SHL will anonymise your Assessment Data, your Results Data, your School Provided Data, and Candidate Data to create SHL Research Data because we have a legitimate interest to create Benchmark Data to develop and improve our services.
We use your Technical and Support Data because we provide technical support to GMAC as well as individuals who reach out to us using our web help form and we have a legitimate business interest in understanding how our assessments are accessed, how they are used and any problems users have with them across multiple devices.
If you require further information regarding our legitimate interests as applied to your personal data, you may contact the SHL Data Protection Officer (DPO) on firstname.lastname@example.org or the contact details included at the end of this Notice.
GMAC and SHL will share your Personal Information with the third parties listed below.
GMAC will store your Personal Information in the United States.
If you have questions about GMAC’s transfer of your Personal Information or the legal basis upon which the transfer is based, please contact GMAC as set forth in the “How to Contact Us” section of this Notice.
As a data processor and as a data controller, SHL stores your Personal Information in production and backup data centers located in the United States and SHL transfers your Personal Information to other SHL affiliates within the European Economic Area (EEA), India, and the United Kingdom (“SHL Non EEA Processing Locations”) where a limited number of our personnel, as well as our trusted third party vendors and service providers, have access to Personal Information in order to provide the services. As the SHL Non EEA Processing Locations are in countries which do not have equivalent data protection laws to those applicable in the EEA, we have an Intragroup Agreement in place, signed by all SHL affiliates, which contains the European Union (EU) Standard Contractual Clauses (SCCs) which have been approved by the EU data protection authorities for the transfer of data outside the EEA. Our third-party vendors and service providers are also required to sign up to SCCs in accordance with Article 46 of the General Data Protection Regulation. All SHL affiliates have the same technical, physical, and administrative security controls and are required to comply with our data protection policies and procedures, applicable laws, governing the collection and use of personal information. SHL will provide a copy of the regulator-approved SCCs, by request to the SHL Data Protection Officer (DPO) at email@example.com or the contact details included at the end of this Notice.
GMAC and SHL will retain your information for as long as needed to provide to provide you with requested services, to meet our governance responsibilities, to comply with legal requirements, for business operations, to protect against fraud and theft, or as otherwise required by applicable law.
Generally, GMAC retains Personal Information for up to 10 years beyond delivery of the last product or service you have ordered or received from us.
SHL retains Personal Information for which it acts as a data controller for a maximum of seven (7) years. Where SHL is acting as a data processor, it retains the data until instructed to delete it by the data controller.
Depending on where you reside, you may have certain rights with respect to your Personal Information. Those rights are described below, and are subject to exemptions under applicable law and will only apply to certain types of information or processing. To exercise these rights, you may contact GMAC or SHL as set forth in the “How to Contact Us” section of this Notice.
If you are not satisfied with our response to your request you also have a right to make a complaint to a supervisory authority regarding the processing.
If you have any questions relating to this Notice or to the processing of your Personal Information by GMAC, or wish to exercise any of your rights under applicable data protection law with respect to GMAC in its role as a data controller, please contact GMAC at firstname.lastname@example.org.
If you have any questions relating to the processing of your Personal Information by SHL in its role as a Data Controller, please contact the SHL Data Protection Officer (DPO) at email@example.com.
Questions about the results of your Assessment or a School’s use of your Personal Information should be sent directly to the School.
This Notice may be updated from time to time. When we make changes, we will update the Effective Date at the top of this Notice. If any of the changes are material, will provide a prominent notice or link to bring your attention to such changes for a reasonable length of time following the change.
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