USA Recruitment Privacy Notice

Last Update: December 2022

This Privacy Notice does not form part of any contract of employment or engagement that you may enter into with us and does not create contractual rights or obligations. It may be amended by us at any time. Nothing in this Privacy Notice is intended to create an employment relationship between us and any non-employee.

Scope of This Privacy Notice

Like most businesses, we hold and process a wide range of information, some of which relates to individuals who apply to work for us, including personal data. This Privacy Notice explains:

what personal data we hold and why we process it;
the sources of personal data;
how long we keep your personal data;
your rights with respect to your personal data; and
how to contact us.

Please note that if you accept an offer from us, the business will process further information as part of the employment relationship and we will provide you with our Workplace Privacy Notice for employees as part of the on-boarding process.

In this Privacy Notice ‘we’, ‘us’ and ‘our’ refers to Omnicom Media Group Holdings, Inc. (“OMG”) and/or the relevant OMG agency that acts as the ‘data controller’ or ‘business’ in respect of your personal data. In the context of this Privacy Notice, the relevant data controller and business of your personal data is the company which you apply to work for.

This Privacy Notice includes the Supplementary Information in the Annex to this document.

In the Supplementary Information, we explain what we mean by “personal data”, “processing”, “sensitive personal data” and other terms used in this Privacy Notice.

Personal data – why we process it

We process your personal data for recruitment, management, administrative, employment and legal related purposes. The Supplementary Information provides more specific information about these purposes, the categories of personal data that may be processed and the sources from which your personal data may have been collected.

How long do we keep your personal data?

In general, we only keep your data for as long as necessary for the purpose for which it was collected and in accordance with the following retention periods:

Successful candidates: if you become employed by us, we will keep your personal data for the duration of your employment with us and then for a certain period of time thereafter (further information will be provided in our Workplace Privacy Notice).
Unsuccessful candidates: if you are unsuccessful in gaining employment with us, we usually keep your personal data for up to 12 months from the date that we received your application, unless you agree that we can retain it for longer (in which case we retain the information for such longer period that you have agreed to).
Other information: certain other information collected in connection with the recruitment process, may be kept for a shorter time period (e.g., CCTV footage data if you attend our premises for an interview) which we will store and delete such data in accordance with our internal retention policies.

In certain limited cases, we may keep your personal data for different periods of time including for periods of time that may not have a finite retention period where such period of time will depend on particular circumstances relating to your personal data (e.g., in the event that it relates to a legal claim). Where there is no finite retention period, we take into account criteria in order to determine how long to retain your personal data including the relevance and usefulness of the personal data to our business and any legal obligations or interest in we have in retaining your personal data (e.g. to exercise or defend against a potential claim).

Consequences of not providing data

When you apply to work for us, some of the personal data that we process about you comes from you. For example, you tell us your contact details and work history. If you do not provide information that we need to evaluate your application or enter into a contract with you, we may not be able to progress through the relevant stage(s) of the recruitment process or enter into a contract with you.

Who we share your data with

We may share your personal data with:

Organizations and service providers that process data on our behalf, e.g., third parties that provide or host our websites, IT systems and information (e.g., our email provider);
third party recruitment consultants and similar businesses (including online recruitment portals) as a part of the recruitment process, particularly where you have applied to us via a recruiter or third party website;
referees, in connection with our referencing processes;
group companies (e.g., where information is shared internally in connection with your application);
disclosure of aggregated and anonymized diversity data to relevant regulators as part of a formal request; and
to third-party organizations in connection with a potential or actual business transaction (e.g., a merger or acquisition).

We will disclose your data if:

where we are required to do so by law,
in connection with criminal, regulatory or an investigation by a public body (e.g., the police); or
with your consent.

Your privacy rights

Depending on the state where you reside, you may have certain choices regarding our use and disclosure of your personal information, including:

Access: You may have the right to request that we disclose to you the personal information we have collected, used and disclosed about you.
Deletion: You have the right to request that we delete certain personal information we have collected from you, where appropriate.
Correction: You have the right to request that we correct or update personal information we have collected from you, where appropriate.
Not to receive discriminatory treatment by us.
Not to be retaliated against for the exercise of your rights.

How to Submit a Request: To submit a request (or to submit a request as an authorized agent on behalf of an individual), email us at or call us at 833-883-0788.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.

If you request access to or deletion of your personal information, we may require you to provide any of the following information: your email address, the name of the Omnicom representative with whom you typically interact, and the date of your last interaction with an Omnicom representative.
In addition, if you ask us to provide you with specific pieces of personal data, we will require you to sign a declaration under penalty of perjury that you are the individual whose personal data is the subject of the request.

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

Contact details and Data Protection Officer

If you have questions about this Privacy Notice or would like to exercise your privacy or data protection rights, please contact us by email at , call us at 833-883-0788, or write to us at:

Omnicom Media Group Holdings Inc.
Attn: Privacy Counsel
195 Broadway, Floor 8
New York, NY 10007

What do we mean by “personal data” and “processing”?

“Personal data” is information relating to you (or from which you may be identified directly or indirectly) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system.

“Processing” means doing anything with the data. For example, it includes collecting it, holding it, disclosing it, and deleting it.

Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to special protection and considered by data protection laws to be “special category data”.

References in this Privacy Notice to employment, work (and similar expressions) include any arrangement we may have under which an individual provides us with work or services, or applies for such work or services.By way of example, when we mention an “employment contract”, that includes a contract under which you provide us with services; when we refer to ending your potential employment, that includes terminating a contract for services. We use the word “you” to refer to anyone within the scope of the notice.

Processing sensitive personal data

We may process sensitive personal data about you for purposes that include:

processing being necessary for the purposes of your or our obligations and rights in relation to employment in so far as it is authorised by law;
processing relating to data about you that you have made public (e.g., if you tell us you are ill);
processing being necessary for the purpose of establishing, making or defending legal claims;
processing being necessary for provision of health care or treatment, medical diagnosis, and assessment of your working capacity; and
processing for equality and diversity purposes to the extent permitted by law.

How do we collect your personal information?

We may have obtained personal data about you from the following categories of sources:

Directly from you, such as when you submit your application
From your devices, such as when you connect to our network
Recruiters or vendors who provide services on our behalf
Social networks, such as LinkedIn
Government entities

Sale of personal data

We do not sell your personal data or share your personal data for purposes of cross-context behavioural advertising.

Further information on the data we process

More specific information on these purposes, examples of the personal data and the third parties to whom personal data may be disclosed are set out in the table below.

The examples in the table cannot, of course, be exhaustive. For example, although the table does not mention data relating to criminal offences, if we were to find out that someone applying to work for us was suspected of committing a criminal offence, we might process that information if relevant for our purposes. In certain circumstances, we may also require criminal background checks (for example, for those working in financial roles).

Purpose	Examples of personal data that may be processed	Categories of third parties to whom personal data may be disclosed
Application and recruitment process administration activities. Administering our recruitment process including processing receipt of your application via our online Careers Portal.	CV information and information you otherwise submit to us in connection with your application (e.g., via our Careers Portal), such as your: Name Contact Details such as phone number (home, mobile and/or work); email address (personal or work, as provided); and address (home and/or work, as provided). Qualifications, skills, and experience such as professional experience and education (including, for example, university degrees, other qualifications, academic records, professional licenses, memberships and certifications, awards and achievements, and current and previous employment details and language skills). Demographic information such as your date of birth, age, nationality, and place of birth. Financial information such as current and expected salary information and remunerated (e.g., day rate), envisaged bonus levels (if applicable) and any other employment or benefits. Other information including any other personal data that you provide us with on your CV or application (e.g., your hobbies and interests). Identity Information such as passport, driver’s license, national identity cards, utility bills and any other information used to verify your identity.	Our affiliates and subsidiaries; vendors who provide services on our behalf such as recruitment agencies; professional services organizations such as auditors and law firms; Internet service providers; government entities; operating systems and platforms.
Evaluating you and your application for the role. Assessing your suitability for the role and reaching a decision including reviewing the information that has been provided to us about you and which we have obtained from interview with you (as applicable). Evaluating your experience and qualifications against the requirements of the position you are applying for.	CV information, in particular your: Qualifications, skills, and experience such as professional experience and education (including, for example, university degrees, other qualifications, academic records, professional licenses, memberships and certifications, awards and achievements, and current and previous employment details and language skills). Financial Information such as current and expected salary information and remunerated (e.g., day rate), envisaged bonus levels (if applicable) and any other employment or benefits. Information you provide to us or we obtain during interview such as your responses to our questions our interview notes and assessments of your application and performance. If necessary, we will also process information concerning your health, any disability and in connection with any adjustments to working arrangements.	Our affiliates and subsidiaries; vendors who provide services on our behalf such as recruitment agencies; professional services organizations such as auditors and law firms; Internet service providers; government entities; operating systems and platforms.
Verifying your identity, right to work and application information. Verifying your identity and the information you have provided as part of the recruitment process including your references and right to work in the jurisdiction.	Name Identity Information such as passport, driver’s license, national identity cards, utility bills and any other information used to verify your identity. CV information and reference related information, in particular, qualification information and previous roles held.	Our affiliates and subsidiaries; vendors who provide services on our behalf such as recruitment agencies; professional services organizations such as auditors and law firms; Internet service providers; government entities; operating systems and platforms.
Communicating with you in connection with the recruitment process. Contacting you in connection with the recruitment process e.g., to confirm interview availability, inform you of the status of your application, respond to queries and questions or communicate acceptance or rejection of your application and making you an offer of employment.	Contact Details such as phone number (home, mobile and/or work); email address (personal or work, as provided); and address (home and/or work, as provided).	Our affiliates and subsidiaries; vendors who provide services on our behalf such as recruitment agencies; professional services organizations such as auditors and law firms; Internet service providers; government entities; operating systems and platforms.
Entering into a contract with you (if you are made an offer by us)	Information on your terms of employment from time to time including your hours and working patterns, your pay and benefits, such as your participation in pension arrangements, life and medical insurance; and any bonus or share schemes.	Our affiliates and subsidiaries; vendors who provide services on our behalf such as recruitment agencies; professional services organizations such as auditors and law firms; government entities; Internet service providers; operating systems and platforms.
Contacting you or others on your behalf	Your address and phone number, emergency contact information and information on your next of kin.	Our affiliates and subsidiaries; vendors who provide services on our behalf such as recruitment agencies; professional services organizations such as auditors and law firms; government entities; Internet service providers; operating systems and platforms.
Payroll administration	Information on your bank account, pension contributions and on tax and national insurance Your national insurance number or other government issued identifier.	Our affiliates and subsidiaries; vendors who provide services on our behalf such as recruitment agencies; professional services organizations such as auditors and law firms; government entities; Internet service providers; operating systems and platforms.
Financial planning and budgeting	Information such as your proposed salary and (if applicable) envisaged bonus levels.	Our affiliates and subsidiaries; vendors who provide services on our behalf such as recruitment agencies; professional services organizations such as auditors and law firms; government entities; Internet service providers; operating systems and platforms.
Monitoring of diversity and equal opportunities	Information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability, and age as part of diversity monitoring initiatives. Such data will aggregated and used for equality of opportunity monitoring purposes. Please note we may share aggregated and anonymized diversity statistics with regulators if formally required / requested.	Our affiliates and subsidiaries; vendors who provide services on our behalf such as recruitment agencies; professional services organizations such as auditors and law firms; government entities; Internet service providers; operating systems and platforms.
Physical and system security	CCTV images upon attendance for interview at our premises.	Our affiliates and subsidiaries; vendors who provide services on our behalf such as recruitment agencies; professional services organizations such as auditors and law firms; government entities; Internet service providers; operating systems and platforms.
Business transactions Providing information to third parties and group companies in connection with transactions that we contemplate or carry out	Information on any offer made to you and your proposed contract and other employment data that may be required by a party to a transaction such as a prospective purchaser, seller or outsourcer.	Our affiliates and subsidiaries; vendors who provide services on our behalf such as recruitment agencies; professional services organizations such as auditors and law firms; government entities; Internet service providers; operating systems and platforms.
Disputes and legal proceedings	Any information relevant or potentially relevant to a dispute or legal proceeding affecting us.	Our affiliates and subsidiaries; vendors who provide services on our behalf such as recruitment agencies; professional services organizations such as auditors and law firms; government entities; Internet service providers; operating systems and platforms.