Privacy
Policy
This privacy statement is effective as of November 2024. This privacy statement is updated regularly to reflect changes in our data handling practices or applicable laws.
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PRIVACY POLICY
This Privacy Policy provides information on the processing of personal data by Career Connections Limited (“the Company”, “we” “us” “our”). This Privacy Policy also explains the rights that you have in relation to the processing activities. The Company is committed to ensuring that your personal data is processed lawfully and in accordance with the Data Protection Act, 2019 (the “Act”) and its Regulations.
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Definitions
Consent”  means any manifestation of express, unequivocal, free, specific, and informed indication of the data subject’s wishes by a statement or by a clear affirmative action, signifying agreement to the processing of personal data relating to the data subject.

Data controller” means an organisation that has full authority to decide how and why personal data is to be processed and has the overall responsibility for the data. This includes deciding on use storage and deletion of the data.

Data subject” means an identified or identifiable natural person who is the subject of personal data.‘‘Data processor’’ means any natural person or organisation or third party that carries out processing of personal data on behalf of the data controller.

Data Commissioner” means the regulator appointed pursuant to the provisions of the Act and whose main responsibility is to oversee the implementation and enforcement of the Act.

Direct marketing” refers to communication, by whatever means, of any advertising or marketing material, which is directed to a data subject using personal data provided by the data subject.

Personal data” means information relating to an identified or identifiable individual/person. An identifiable individual is one who can be identified directly or indirectly in particular reference to an identifier such as a name, identification number, location data, an online identifier (etc.)

Personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.

Processing” means any operation or sets of operations which is performed on personal data or on sets of personal data whether or not by automated means, such as:collection, recording, organisation, structuring;storage, adaptation or alteration;retrieval, consultation or use;disclosure by transmission, dissemination, or otherwise making available; oralignment or combination, restriction, erasure or destruction.

Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's race, sex, pregnancy, marital status, health status, ethnic social origin, colour, age, disability, religion, conscience, belief, culture, dress, language or birth; personal preferences, interests, behaviour, location or movements.

Sensitive personal data”  means data revealing the natural person's race, health status, ethnic social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details including names of the person's children, parents, spouse or spouses, sex or the sexual orientation of the data subject.
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Purpose of this Privacy Policy
To perform our functions, we need to collect certain personal data and sensitive personal data. This Privacy Policy:

a) sets out the types of personal data that we collect about you;
b) explains how and why we collect and use your personal data;
c) explains how long we keep your personal data;
d) explains when, why and with who we will share your personal data;
e) sets out the legal basis we have for using your personal data;
f) explains the effect of refusing to provide the personal data required;
g) explains the different rights and choices you have when it comes to your personal data;and
h) explains how we may contact you and how you can contact us.
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Application of this Privacy Policy
This Privacy Policy applies to the processing of personal data by the Company’s visitors and users of the Company’s various sites, candidates, participants, employees, attendees of the Company’s events, clients and prospective clients and their representatives, subscribers to the Company’s publications or newsletters or mailing list, visitors to the Company’s facilities and suppliers and business partners and their representatives (referred to as “you” or “your” in this Privacy Policy).
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The personal data collected
The Company collects personal data directly from you as well as from other available sources to the extent permitted by law.

The Company endeavours to collect only that Personal Data that is necessary for the purpose(s) for which it is collected and to retain such data for no longer than necessary for such purpose(s). Subject to applicable law and practice, the categories of personal data that are typically collected and processed include, but are not limited to:

Candidates: We collect your name, contact information (email addresses and telephone numbers), curriculum vitae information and personality and psychrometric tests assessment information (where applicable).

Participants: We collect your name, contact information (email addresses and telephone numbers) and personality and psychrometric tests assessment information (where applicable).

Clients: We collect your name, contact details or the details of individual contacts at your organisation, your designation, country of residence and KRA PIN.

Employees: We collect your name, contact information (email addresses and telephone numbers), ID/Passport number, KRA PIN details, NHIF details, NSSF details, HELB details, bank account details, next of kin details, photo, social media details, education certificates, credit information, pension and medical onboarding information and residential information.

Associates, Suppliers and Partners: We collect your name, contact details or the details of individual contacts at your organisation, your bank details and KRA PIN.

Alumni: We collect your name and contact details (email addresses and telephone numbers) and Kenya Revenue Authority Personal Identification Number (KRA PIN).
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How the personal data is collected
We may collect personal data directly from you. For example, we collect data from you when:

a) you correspond with us by phone or by email;
b) you visit our offices; and
c) you visit our website.

We may also collect personal data indirectly from you. For example, we collect data from you when:

a) where the data is contained in a public record;
b) where you have deliberately made the data public;
c) where you have given, us consent to collect the data from another source;
d) from third parties who collect information about you on behalf of the Company;
e) where you have an incapacity, and your appointed guardian has consented to the collection from another source;where the collection from another source is necessary;
f) for the prevention, detection, investigation, prosecution, and punishment of crime;
g) for the enforcement of a law which imposes a pecuniary penalty; or
h) for the protection of the interests of a data subject or another person.
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Uses of your personal data
Candidate data: We process personal data to, among others:

a) assess your suitability for the roles that seek to be filled by the clients;
b) undertake the recruitment process;
c) undertake personality and psychometric tests and thereafter generate reports for the clients;
d) undertake background checks and generate reports for the clients;
e) effectively communicate and coordinate during the recruitment process; and

Participant data: We process personal data to, among others:

a) offer the requested services, for example, talent development, coaching, training etc.;
b) undertake personality and psychometric tests and generate reports for the participants and/or clients;
c) effectively communicate and coordinate during the talent development process; and

Client data: We process personal data to, among others:

a) undertake the Know-Your-Customer process;
b) enter into service contracts;
c) effectively communicate and coordinate when offering services;
d) share information through our marketing campaigns;
e) share information about our events;
f) make tax payments and returns; and

Employee data: We process personal data to, among others:

a) assess your suitability for the role we seek to fill internally;
b) enter into an employment contract with you;
c) populate your employee file;
d) undertake the payroll process;
e) collect emergency contact details;
f) undertake background and reference checks;
g) onboard you on our pension and medical schemes;
h) celebrate your birthday; and
i) complete the employee details form.

Associates, Supplier and Partner data: We process personal data to, among others:

a) enter into supplier and partner contracts;
b) make the necessary payments;
c) effectively communicate and coordinate during the contract period;
d) share information about our marketing campaigns;
e) share information about our events;
f) make tax payments and returns; and

Alumni data: We process personal data to, among others:

a) effectively communicate and coordinate;
b) share information about our events; and

We also process personal data to:

a) communicate and respond to your requests and inquiries to the Company;
b) to engage in transactions with business partners;
c) to analyse, develop, improve and optimize the use, function and performance of our sites and products and services;
d) to manage the security and operation of our sites, facilities and networks and systems;
e) to operate our business;
f) to analyse the trends in our sector of operation;
g) for research purposes;
h) for marketing purposes in collaboration with our marketing agents;
help us establish or defend legal claims; and
i) to comply with applicable laws and regulations.

OUR LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA
The Company processes your personal data for the following lawful bases:

a) where you consent to the processing for one or more specified purposes; or
b) where the processing is necessary;
c) for the performance of a contract to which you are a party or to take certain steps at your request before entering a contract;
d) for compliance with any legal obligation to which we are subject;
e) to protect your vital interests or that of another person/individual;
f) to enable us to perform a task carried on in public interest or in the exercise of official authority vested in us; and
g) for our legitimate interest.

SHARING OF YOUR PERSONAL DATA
Any disclosure of your personal data shall be in accordance with applicable law and regulations. We may disclose your personal data to:

a) potential employers, where you are a candidate.
b) individuals and organisations who hold information related to your reference such as current, past or prospective employers, referees, educators and examining bodies.
c) tax or other authorities when we believe in good faith that the law or other regulation requires us to share this data.
d) service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, partners for assessment tools and training solutions, administration functions, technical and support functions and IT consultants carrying testing and development work on our systems).
e) third party outsourced IT and document storage providers.
debt-collection agencies or other debt-recovery organisations.
f) relevant third parties in the event of a reorganisation, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
g) emergency service providers where such disclosure to emergency service providers is necessary for your rescue, health and safety, including your approximate location.

SAFEGUARDING YOUR PERSONAL DATA

We care about protecting your personal data. That is why we have put in place appropriate measures that are designed to prevent personal data breaches. We do this by having in place a range of appropriate technical and organisational measures including measures to deal with any suspected personal data breaches.

If you suspect any misuse or loss of or unauthorized access to your personal data, please let us know immediately by contacting us.

STORAGE OF YOUR PERSONAL DATA

We will only keep your personal data for as long as it is necessary to achieve the purposes for which it was required unless the retention is required or authorized by law, reasonably necessary for a lawful purpose, you have consented to longer retention periods or if the personal data is required for auditing or compliance purposes.

THE RIGHTS YOU HAVE OVER YOUR PERSONAL DATA

The Act accords you several rights over your data.

a) right to information: you have a right to be informed of how the Company will use your personal data.

b) right of access: you are entitled to access your personal data that is in our possession or custody.

c) right to object: you can object to the processing of all parts of your personal data, unless we can demonstrate: a compelling legitimate interest for the processing which overrides your interests: orthat we are processing your personal data for the establishment, exercise or defense of a legal claim.

d) right to rectification: you have the right to request us to rectify or correct, personal data in our possession or under our control that is inaccurate, outdated, incomplete or misleading.

e) right to erasure: you can request us to delete or destroy personal data that we are no longer authorized to retain, or which is irrelevant, excessive, or obtained unlawfully.

d) right to data portability: you have the right to receive personal data concerning you in a structured, commonly used and machine-readable format and to transmit the data to another data controller without hinderance. Where technically possible, have personal data transmitted directly from us to another data controller or data processor.automated decision making you have the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning or that significantly affects you. Career Connections may from time to time make decisions based on automated processing of your personal data. In such instance, you will be informed, in writing, whenever a decision based on automated processing is taken. In addition, you can request us to reconsider any decisions made based on automated processing or to take a new decision that is not based solely on automated processing.

e) right of restriction: You have the right to request us to restrict the processing of personal data where: you contest the accuracy of the personal data.the personal data is no longer required for the purpose of the processing.the processing is unlawful, or you are opposed to the erasure of the personal data and requested for restriction of its use instead.you have objected to the processing of personal data, pending verification as to whether the legitimate interests of the data controller or data processor overrides those of the data subject.

f) right to raise a complaint: You can raise a complaint about the processing of your personal data.

If you wish to exercise any of our rights above, please contact us using our contact address. We will endeavour to deal with your request without undue delay. We may ask for identification to ascertain whether we are issuing the data to the right person.

COMPLAINTS MANAGEMENT

If you have any complaint regarding our compliance with this Privacy Policy, please contact us. We will investigate and attempt to resolve complaints and disputes regarding use of personal data in accordance with our policies and the applicable law. You also have the right to file a complaint with the Office of the Data Protection Commissioner.

INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA

To provide you with the best services and carry out the purposes outlined in this Privacy Policy, we may need to transfer your personal data;

a) to our oversees partners or service providers;
b) to oversees clients; or
c) to cloud-based storage providers.

We will only transfer your data outside Kenya where such transfer is compliant with the provisions of the Act.

To ensure that your personal data receives adequate levels of protection, we shall put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal data is treated by those third parties in a way that is consistent with, and which respects the data protection laws.
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Cookies
A "cookie" is a bite-sized piece of data that is stored on your computer's hard drive. They are used by nearly all websites and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.

Our website only uses first-party cookies. We use the cookies to:

a) assign a randomly generated number as a client identifier so that no name is attached to the analytics;
b) calculate visitor, session and campaign data for the site’s analytics reports;
c) count and track pageviews; and
d) collect the behavioural data of all website visitors.

This includes pages viewed, visitor source and time spent on the site. Our website does not collect any personal data.
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Updates to this Privacy Poicy
The Company reserves the right to amend or modify this Privacy Policy at any time. If we amend this Policy, you can access the most current version of the policy on our website. Any amendment or modification to this statement will take effect from the date of notification on our website. Your use of our website following an update means that you accept the revised Privacy Policy.
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Direct marketing
You can opt out of our mailing list at any time by contacting us and asking us to stop sending you our marketing emails. Our opt-out process will be simple and free of charge.Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service already signed up for.
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Third party sites
Our websites may provide links to other locations or websites on the Internet. These links lead to websites published or operated by third parties who are not affiliated with or in any way related to us and have been included in our website for your convenience.By clicking on a hyperlink, you will leave the Company’s webpage and accordingly you shall be subject to the privacy policies of the other website that you choose to visit and not this Privacy Policy.
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Your responsibilities
You are responsible for the personal data you make available to the Company, and you must ensure it is accurate, honest, truthful, and not misleading in any way. You remain liable for any claims, damages or loss that may occur due to your provision to the Company of inaccurate information. You will be required to indemnify the Company for any third- party claims that may arise thereto.

You must also ensure that the personal data you provide the Company does not contain material that is obscene, defamatory, or infringing on any rights of any third party.

Further, if you provide any personal data concerning any other person, such as individuals you provide as references (“referee”), you are responsible for providing any notices and obtaining any consents necessary for the Company to collect and use that personal data before you provide the referee’s personal data to the Company.

Should you choose to withhold your personal data, for any reason whatsoever, the Company will be unable to provide you with the services requiring the personal data withheld.
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Our contact details
We welcome your questions, inquiries, comments, and concerns about privacy. If you have any questions about this Privacy Policy or our personal data processing practices, you can contact the Company using this email address privacy@careerconnectionsltd.com.

The Company’s offices are located at: KAM Building, Mwanzi Road, Westlands, P.O Box 25118-00603 Nairobi.Your privacy is important to us!
DATA PROTECTION FAQs
At Career Connections Limited (“we,” “us,” or “our”), we are committed to processing your personal data fairly, transparently, and in compliance with Kenya’s Data Protection Act, 2019.
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What is personal data?
"Personal data" refers to any information that relates to an identified or identifiable individual. This may include names, email addresses, phone numbers, resumes, employment history, educational qualifications, and other details you submit via our website or during communication.
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How do we collect your personal data?
We collect personal data when you:

a) Submit applications or CVs;
b) Fill forms to register for services, newsletters, or events;
c) Reach out via our website, email, or phone; or
d) Are recommended through partners or referees, where permitted by law.
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Why do we collect your data?
We process your data to:

a) Manage recruitment, coaching, and training services;
b) Manage any events (online or physical) that you in participant in
c) Respond to your inquiries and deliver requested services;
d) Comply with legal and regulatory obligations; and
e) Communicate with you, where consent has been provided.
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With whom do we share your data?
We may share your data with:

a) Clients and partners engaged for recruitment or assessments;
b) Service providers (e.g., IT, psychometric testing, email services);
c) Regulatory or legal authorities when required by law.

These third parties are bound by contractual obligations to process your data in line with applicable data protection standards.
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Do you transfer my data outside Kenya?
If necessary, your data may be transferred to jurisdictions with adequate data protection safeguards or under contractual and organizational controls to ensure continued protection, as per Kenyan law.
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How long do you keep my data?
We retain your personal data only as long as needed for its original purpose or as required by law. Once no longer necessary, your data will be securely deleted or anonymized.
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What rights do I have under the Data Protection Act, 2019?
You have the right to:

a) Access your personal data;
b) Correct or update it;
c) Request deletion or restriction of processing;
d) Object to processing or withdraw consent;
e) Request data portability;
f) Lodge a complaint with the Office of the Data Protection Commissioner.
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How can I exercise my data rights?
To exercise any of your data rights, contact our Data Protection Officer at:
Email: privacy@careerconnectionsltd.com. We may request proof of identity before processing your request in accordance with applicable law.
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How do we safeguard your data?
We implement appropriate technical and organizational measures—including access controls, secure servers, encryption, and staff preparedness—to protect your personal data from unauthorized access, alteration, or disclosure.
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Where can I get more information?
If you have any questions or concerns about our data practices, please contact:

Career Connections Limited
Email
: privacy@careerconnectionsltd.comAddress: KAM Plaza, Mwanzi Road, Westlands.
TERMS AND CONDITIONS
These Terms and Conditions ("Terms") govern your use of the website www.careerconnectionsltd.com ("Website"), operated by Career Connections Limited ("the Company", "we", "us", or "our"). By accessing, browsing, or using this Website, you acknowledge that you have read, understood, and agree to be bound by these Terms. If you do not agree with these Terms, you must discontinue use of the Website immediately.
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Changes to Terms
We reserve the right, at our sole discretion, to modify, amend, or replace these Terms at any time. Any such changes will become effective immediately upon posting on the Website. Your continued use of the Website after the posting of revised Terms constitutes your acceptance of such changes.
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Permitted use and user conduct
You agree to use the Website solely for lawful purposes and in a manner that does not infringe the rights of, restrict, or inhibit the use and enjoyment of the Website by any third party. Prohibited conduct includes, but is not limited to:

a) Engaging in any unlawful, fraudulent, or harmful activity;
b) Uploading or transmitting viruses, malware, or harmful code;
c) Attempting to gain unauthorized access to the Website, servers, or associated systems; and
d) Impersonating any person or entity.

Career Connections in its sole discretion shall determine your compliance with the above and shall have the right to prevent you from using the Site and/or to delete from the Site immediately and without prior notice any material that it deems not to comply or to be objectionable for any reason. As the services on the Site are made available to users and employers immediately, you do not enjoy any cancellation or “cooling-off” rights in relation to these Terms of Use.
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Links to or from other sites
As a convenience to users, this Site contains links to external websites and you may be offered a number of automatic links to other sites, which may interest you. We accept no responsibility for or liability in respect of the content of those sites. Hays should not be taken as having reviewed or approved such sites or their contents, nor does it warrant that any links to such sites work or are up to date. The use of any such links is entirely at your own risk. Any third parties wishing to link to our Site may do so provided links are to the home page only of the Site and provided we are notified in advance by email to info@careerconnectionsltd.com
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Intellectual property rights
All of the information contained on this Site is the © of Career Connections Limited. All trade marks, logos, software or any other or any other of its intellectual property rights are the exclusive property of Career Connections Limited. You may not download, copy or print any of the pages of the Site except for your own personal use, and provided you keep intact all copyright and proprietary notices. No copying or distribution for any business or commercial use is allowed. No framing, harvesting, “scraping” or other manipulation of the content of the Site is permitted. You will not attempt to decipher, disassemble, reverse engineer or modify any of the software, coding or information comprised in the Site; nor will you post to the Site any material which infringes any intellectual property rights of any third party.
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Disclaimer and limitation of liability
The Website and all content, materials, products, and services made available through it are provided on an “as is” and “as available” basis, without any representations or warranties of any kind, whether express, implied, or statutory, including but not limited to implied warranties of merchantability, fitness for a particular purpose, non-infringement, accuracy, completeness, reliability, security, or availability.

We do not warrant that:

a) the Website will function uninterrupted, be secure, or be free from errors, defects, viruses, malware, or other harmful components;
b) the information provided is accurate, up-to-date, complete, or suitable for any particular purpose; or
c) any defects or errors will be corrected within a specific timeframe.

To the fullest extent permitted by applicable law, Career Connections Limited, its directors, officers, employees, agents, contractors, and affiliates shall not be liable for any loss, damage, claim, cost, or expense of any nature whatsoever, including without limitation:

a) direct, indirect, incidental, special, punitive, or consequential damages;·
b) loss of revenue, profits, business, contracts, opportunities, data, goodwill, or anticipated savings;·
c) any damages arising from your reliance on any content or services provided through the Website;·
d) any damages related to the use of third-party links, websites, or resources accessible from our Website; or
e) any damages resulting from unauthorized access to or alteration of your transmissions or data.

You acknowledge that you use the Website and its content at your own discretion and risk, and you are solely responsible for ensuring that any content, services, or products available through the Website meet your specific requirements and are free from harmful elements.

Nothing in these Terms shall exclude or limit liability for death or personal injury caused by negligence, fraud, fraudulent misrepresentation, or any other liability which cannot be excluded or limited under applicable law.
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Termination
We may at our absolute discretion deny you access to this Site (which may include any of the services or information available through it) or any part of it at any time without explanation.
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Governing law
These Terms shall be governed by and construed in accordance with the laws of the Republic of Kenya. Any dispute arising under or in connection with these Terms shall be subject to the exclusive jurisdiction of the courts of Kenya.
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Contact information
If you have any questions or concerns about these Terms, please contact us at:

Career Connections Limited:
Email: info@careerconnectionsltd.com
Address: KAM Plaza Mwanzi Road, Westlands, Nairobi.
INTRODUCTION
Career Connections Limited ("we," "us," or "our") respects the privacy of candidates applying through our platform. This policy outlines how we collect, use, and protect personal information provided by candidates throughout the recruitment and assessment process.
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Who Are We?
Career Connections Ltd is a premier human capital consulting firm specializing in executive search, leadership development, talent assessment, and organizational effectiveness solutions. Based in Nairobi, Kenya, we serve a broad range of clients across the private, public, and non-profit sectors in the region and beyond.

As part of our service offering, we collect, process, and store personal data of candidates, employees, coaching participants, and other stakeholders in order to facilitate recruitment processes, conduct assessments, deliver coaching and training programs, and support organizational development initiatives. In delivering these services, we are committed to protecting the privacy and personal data of all participants in accordance with applicable data protection laws, including the Kenya Data Protection Act, 2019.
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Who Does The Policy Apply To?
This Candidate Privacy Policy applies to all individuals who engage with Career Connections Ltd in relation to recruitment, executive search, talent assessment, and related services. This includes, but is not limited to:·    
a) Job applicants and candidates undergoing recruitment processes;·      
b) Individuals participating in psychometric or leadership assessments;·      
c) Persons receiving coaching or leadership development services as part of a client engagement;·      
d) Any other individuals whose personal data is collected or processed as part of our talent and organisational solutions.
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What is The Purpose of This Policy?
To perform our functions, we need to collect certain personal data and sensitive personal data. This Privacy Policy:
a) sets out the types of personal data that we collect about you;
b) explains how and why we collect and use your personal data;
c) explains how long we keep your personal data;
d) explains when, why and with who we will share your personal data;
e) sets out the legal basis we have for using your personal data;
f) explains the effect of refusing to provide the personal data required;
g) explains the different rights and choices you have when it comes to your personal data; and
h) explains how we may contact you and how you can contact us.
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What Information Do We Collect From Candidates?
During the recruitment and assessment process, we may collect the following information:
a) Personal Data: This includes your name, contact details (such as email address, phone number), and other identifying information.
b) Professional Information: Details such as your work history, education, certifications, skills, and references.
c) Background Information: We may receive information from third-party sources such as former employers, academic institutions, professional referees, and background screening providers (e.g., criminal record checks, credit history, or verification of academic/professional credentials), as permitted by law.
d) Assessment Information: Results from any psychometric tests, assessments or interviews, as well as feedback from interviewers and assessors or recruitment panels.
e) Client-Provided Information: In some cases, our clients may share information about the role you are being considered for, their specific evaluation criteria, or feedback following interviews or assessments.
f) Career Preferences: Information relating to your job interests, preferred industries or sectors, desired roles, availability, and compensation expectations.
g) Coaching and Development Data: Insights collected through coaching engagements, including development goals, session notes, self-assessments, and feedback from coaching sessions or leadership development programs.
h) Other Information:
Any additional details you voluntarily provide in your resume, cover letter, application forms or during verbal communications.
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How Do We Collect You Personal Data?
We collect your personal data through various lawful and transparent means, including:

A. Directly from You:
We collect your personal data directly from you when you:
i) submit your CV, application form, or other related documents
ii) participate in interviews, assessments or coaching sessions; or
iii) communicate with us during the recruitment, coaching or executive search process.

B. From Third Parties and other sources
We may also collect your personal data from other sources, including:
i)
Referees and professional references
ii) Background check providers
iii) Our clients who may recommend or refer candidates for specific roles, including executive or board positions
iv) Publicly available sources, such as professional networking platforms (e.g., LinkedIn)
v) Public records, where the data is lawfully available
vi) Where you have deliberately made the data public
vii) Where you have given consent to collect the data from another source
viii) Where you are incapacitated, and your appointed guardian has consented to the collection from another source
ix) Where collection from another source is necessary for the prevention, detection, investigation, prosecution, or punishment of a crime
x) Where required for the enforcement of a law that imposes a pecuniary penalty.
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How Do We Use Your Information?
We use your personal data for legitimate business purposes in connection with our recruitment, assessment, coaching, and talent development services. Specifically, we may use your information to:
a) Manage and administer the recruitment and assessment process, including shortlisting, interviewing, testing, and reference checks.
b) Evaluate your qualifications, skills, experience, and suitability for specific job opportunities or assignments.
c) Communicate with you regarding your application status, upcoming assessments, interviews, and related updates.
d)Share your profile, CV, and assessment results with our clients for consideration for current or future employment or executive leadesrhip opportunities.
e) Comply with legal and regulatory obligations, including diversity and equal opportunity monitoring where applicable.
f) Verify the accuracy and integrity of the information you provide, including professional, financial, and reputational checks where appropriate for leadership roles.
g) Maintain records of recruitment and executive placement activities for business continuity, audit, reporting, and legal compliance purposes.
h) Analyse and improve our recruitment, executive search, and assessment processes, tools, and methodologies.
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What Is Our Legal Basis For Processing Your Data?
We rely on the following legal bases to process your personal information, in accordance with the Kenya Data Protection Act and other applicable data protection laws:

Consent – We may rely on your consent to process certain types of personal data, such as sharing your profile with clients, conducting background checks, or administering assessments. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Performance of a Contract or Pre-Contractual Steps – We process your data when it is necessary to take steps at your request before entering into a contract, or to perform a contract to which you are a part, such as facilitating your participation in a recruitment, coaching, or assessment process.

Legitimate Interests – We may process your data where it is necessary for our legitimate business interests, such as evaluating your suitability for roles, improving our recruitment services, or maintaining business records. We ensure that such interests are not overridden by your rights and freedoms.

Compliance with Legal Obligations – We may process your information where necessary to comply with applicable laws and regulatory requirements, including employment, anti-discrimination, and health and safety laws.

Public Interest - In limited cases, where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority, particularly with regard to senior or public sector appointments.

If we need to process any special categories of personal data (such as health data or data revealing racial or ethnic origin), we will do so only where permitted by law and, where necessary, with your explicit consent.
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Who Do We Share Your Data With?
We may share your personal data with selected third parties where necessary for the purposes outlined in this policy and in accordance with applicable data protection laws. These include:
Our Clients:
We may share your CV, profile, assessment results, and other relevant information with clients who are recruiting or seeking candidates for employment, executive, or board-level positions.

Referees and Background Check Providers: We may contact your referees and engage third-party service providers to conduct background checks, credential verifications, and other relevant screenings, with your knowledge and, where required, your consent.

Assessment and Coaching Partners: Where applicable, we may share limited data with accredited assessors, coaches, or external consultants involved in delivering assessment, leadership development, or coaching services.

Technology and System Providers: We may share your data with trusted third-party vendors who provide us with IT systems, applicant tracking platforms, or psychometric assessment tools, strictly for the purpose of supporting our services.

Regulatory or Legal Authorities:
We may disclose your data where required to comply with legal obligations, regulatory requirements, or lawful requests by public authorities.

Professional Advisors: In limited cases, we may share your data with legal, audit, or compliance advisors in connection with our legal obligations or the protection of our legitimate interests.
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How Long Do We Retain Your Data?
a) We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to:
- Support current or future recruitment, assessment, or coaching opportunities
- Comply with legal, regulatory, contractual, or reporting obligations
- Maintain business and operational records, including for audit or dispute resolution purposes
b) Where you are not selected for a specific role, we may retain your profile in our talent database for a defined period in order to match you with future opportunities—unless you request its deletion.
c) We periodically review the personal data we hold and securely delete or anonymize it when it is no longer needed.
d) The specific retention periods may vary depending on the nature of the data, the services provided, and applicable legal requirements. If you would like more information about our data retention practices or wish to request deletion of your data, you may contact us using the details provided in this policy
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How Do We Secure Your Data?
We take the security of your personal data seriously and implement appropriate technical and organizational measures to protect it from unauthorized access, loss, misuse, alteration, or disclosure. These measures include:
Access Controls: Limiting access to personal data to authorized personnel only, based on role and need-to-know basis.

Data Encryption:
Using encryption protocols to safeguard data during transmission and, where applicable, at rest.

Secure Systems:
Storing data in secure systems with firewalls, antivirus protection, and regularly updated security configurations.

Staff Training:
Regular training of our staff and consultants on data protection principles, confidentiality, and secure handling of personal information.

Contracts with Third Parties:
Ensuring that any third-party service providers we engage are bound by strict data protection and confidentiality obligations.

Physical Security:
Implementing physical access controls in our offices and restricting entry to secure areas.

Regular Reviews:
Conducting regular audits and reviews of our data protection policies, practices, and systems to ensure ongoing compliance and effectiveness.

While we take all reasonable precautions to protect your data, please note that no method of transmission over the internet or electronic storage is entirely secure. However, we remain committed to continuously improving our security practices in line with technological developments and legal requirements.
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Your Rights
As a data subject, you have specific rights under the Kenya Data Protection Act, 2019. These rights are designed to give you greater control over your personal data. They include the right to:
a)Access Your Data: Request confirmation as to whether we hold personal data about you and access to that data.
b) Request Correction: Ask us to correct or update any inaccurate or incomplete personal data we hold about you.
‍c) Request Deletion: Request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you have withdrawn your consent (where consent was the legal basis for processing).
‍d) Object to Processing: Object to the processing of your personal data where we are relying on legitimate interests, unless we have compelling legitimate grounds to continue.
‍e) Request Restriction of Processing: Ask us to temporarily suspend processing of your personal data under certain circumstances.
‍f) Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing carried out before withdrawal.
‍g) Data Portability: Request to receive your personal data in a structured, commonly used, and machine-readable format and to have it transferred to another data controller, where technically feasible.
‍h) Lodge a Complaint: Lodge a complaint with the Office of the Data Protection Commissioner if you believe your data protection rights have been violated.

To exercise any of these rights, please contact us using the contact details provided in this policy. We may need to verify your identity before processing your request
.
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International Data Transfer
In some instances, your personal data may be transferred to and processed in countries outside Kenya, including where:
- Our clients, service providers, or technology partners are located in other jurisdictions; or
- Cloud-based systems or platforms used to deliver assessments, coaching, or recruitment services are hosted internationally.

Where such transfers occur, we ensure that your personal data is afforded an adequate level of protection, consistent with the requirements of the Kenya Data Protection Act, 2019. This may include:
- Ensuring the receiving country has data protection laws offering an adequate level of protection
- Entering into data transfer agreements or standard contractual clauses with the receiving parties
- Obtaining your explicit consent where appropriate  

We take all reasonable steps to ensure that any international transfer of your personal data is secure, lawful, and limited to what is necessary for the purposes outlined in this policy.
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Your Responsibilities
While we are committed to protecting your personal data, you also have responsibilities to ensure the integrity and accuracy of the information you provide. As a candidate, you are expected to:
Provide Accurate and Complete Information:
Ensure that all personal data, qualifications, and background details submitted to us are truthful, complete, and up to date.

Update Your Information:
Inform us promptly of any changes to your personal data, such as contact details, employment history, or referees, to keep your records current.

Respect Confidentiality:
Maintain the confidentiality of any proprietary, client, or assessment information you may access during the recruitment or coaching process.

Use Our Platforms Responsibly:
Where applicable, access our digital platforms or tools only for their intended purpose and in a secure and respectful manner.

Failure to provide accurate or complete information may impact your candidacy, the validity of assessment outcomes, or our ability to deliver services to you or our clients.
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Cookies and Website Tracking
If you access our services through our website, please note that we may use cookies or similar technologies to enhance user experience and track usage. Please refer to our Cookie Policy for more information.
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Changes To This Privacy Policy
We may update this policy periodically to reflect changes in our practices or legal requirements. The latest version will be available on our website, with the last revision date noted below.
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Contact Details
If you have any questions, requests, or concerns regarding your personal data or this policy, please contact our Data Protection Officer on privacy@careerconnectionsltd.com.
INTRODUCTION
Career Connections processes personal data relating to Coachee (“You” Your”). With regard to such processing, the Company qualifies as a “Data Controller”. In this capacity, we strive to comply with the applicable Data Protection Laws in Kenya by protecting your privacy when dealing with your personal data.
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Who Are We?
Career Connections is a leading consulting firm in East Africa founded in 1997 which helps organisations hire, develop and retain the best people through expertise in executive search, talent assessments, team and leadership development, as well as executive coaching.
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Purpose Of This Policy
The Company collects and processes personal data relating to Coachee during the Leadership and coaching process. We are committed to being transparent about how we collect, use that data and how we meet the data protection obligations.

This Coachee Privacy Policy:·      
a) sets out the types of personal data we collect about you·      
b) explains how and why we collect and use your personal data·      
c) explains how long we keep your personal data for·      
d) explains when, why and with who will we share your personal data·      
e) sets out the legal basis we have for using your personal data·      
f) explains the effect of refusing to provide the personal data collected·      
g) explains the different rights and choices you have when it comes to your personal data·      h) explains how we may contact you and how you can contact us
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Who Does This Policy Apply To?
This Coachee Privacy Policy applies to all individuals who take up CCL coaching services.
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What Personal Data Do We Collect About You?
We collect a range of information about you which includes:
Personal Identification Information: name, username ID, identification card or and passport number/copies
Contact Details: telephone numbers, email addresses and location details    
Meeting Details: dates, times and notes  
Contracts information: information contained in your contract with CCL    
Performance data:  assessment data, organisational performance and feedback data    Customer experience: through customer
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How Do We Collect You Personal Data?
- Directly from your when you interact with our coaching services.

- Indirectly from sources such as LinkedIn, Clients, Partners, Associates or Referrals. Where we collect your data indirectly, we will endeavour to inform you of such collection within fourteen (14) days
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How Do We Use Your Information?
We will use the personal data we collect about you to:
a) Contact client to discuss project execution, report on project progress and request additional input from clients.  
b) Align with your on session attendance and participation.  
c) Record session attendance of the participants.
d) Make sure your correct details are captured in the system.
e) Match the services provided against the invoice shared by you.
f) Manage your relationship with the Company.
g) Track your attendance, participation and participant progress.
h) Improve the process.
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What Is Our Legal Basis For Processing Your Data?
We collect and use your personal data on the following legal basis:
a) Performance of a contract in which you are entering or have entered.
b) Consent that you shall have provided to us.
c) Legitimate interest for keeping records of the process.
d) To fulfil our vital interests e.g. in case of a medical emergency when on our premises.

Where processing of your personal data is based on consent, you have the right to withdraw consent at any time. Such withdrawal of consent shall not affect the lawfulness of the processing based on consent before the withdrawal.
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Who Do We Share Your Data With?
We share your personal data to the extent necessary and in compliance with Kenya Data Protection Laws with Coaches, Client’s contact person, external associates, alumni, partners and CCL’s authorised employees.
       
When sharing your data with third parties, we ensure that they adhere to strict data protection and confidentiality standards. We conduct due diligence on our third-party providers and require them to implement similar data protection measures, including secure data storage, access controls, and compliance with relevant data protection regulations. Additionally, we enter into data processing agreements with these third parties to ensure the safeguarding of your personal data
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How Do We Safeguard Your Personal Data?
We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused, or disclosed, and that it is only accessed by authorized personnel for legitimate purposes. These measures include:    
a) Password protection on all laptops and devices used by employees.      
b) Non-disclosure agreements (NDAs) and/or contracts signed by Career Connections team members, restricting the sharing of your data.    
c) Access control measures, ensuring that only authorised employees have access to specific data.
d) Use of firewalls, intrusion detection and other network security measures.
e) Regular software updates to protect against vulnerabilities.
f) Regular data security audits      
g) Physical security measures such as locked filing cabinets, CCTV cameras, secure disposal and key management policies.
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What Rights Do You Have Over Your Data?
You have the following rights over your personal data: ·      
Right to Access: You have the right to request access to the personal data we hold about you and to obtain a copy of it

Right to Rectification: You can request that we correct or update any inaccurate or incomplete personal data.    
 
Right to Erasure: You have the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent (if applicable).

Right to Objection: You can object to the processing of your personal data based on legitimate interests, or for direct marketing purposes.    

Right to Restriction: You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest its accuracy or if you believe the processing is unlawful.

Right to Data Portability: You can request to receive your personal data in a structured, commonly used, and machine-readable format, and to transfer it to another data controller, where technically feasible.
   
Right to Withdraw Consent: If we process your data based on your consent, you have the right to withdraw your consent at any time, which will not affect the lawfulness of processing based on consent before its withdrawal.

Right to Lodge a Complaint: You have the right to lodge a complaint with the Data Commissioner if you believe your data protection rights have been violated.
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What If You Do Not Provide Personal Data?
You are under no statutory or contractual obligation to provide data to the Company to undergo the leadership and coaching process. However, if you do not provide the information, the Company may not be able to:
-
Fulfill the contractual obligations you have entered into or shall enter into.
- Comply with legitimate interests such as keeping records of the process.
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International Data Transfer
To generate reports or onboard participants onto projects, your data may be shared with the Company’s partners whose cloud-based system service providers are located outside Kenya such as Kaiser, Hogan, Talogy, AoEC, etc.

We will only transfer your personal data outside Kenya where such transfer is compliant with the provisions of the Data Protection Act 2019 and the Data Protection (General) Regulations, 2021.
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How Do You Exercise Your Rights?
If you wish to exercise any of the rights outlined above, please draft an email to the Data Protection Officer (DPO) on Privacy@careerconnectionsltd.com In some cases, we will not be able to comply with your request. If this happens, you will be duly notified.
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Policy Review
This Coachee Privacy Policy shall be reviewed annually by the DPO and approved by the Board of Directors.
INTRODUCTION
Career Connections Ltd (“We,” “Our,” or “Us”) is committed to protecting the personal data of individuals who register for or attend our events, workshops, webinars, and similar forums (“you” or “participants”). This Privacy Policy outlines how we collect, use, share, and protect your personal data in connection with our events.
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Who Are We?
Career Connections Ltd is a premier human capital consulting firm specialising in executive search, leadership development, talent assessment, and organizational effectiveness solutions. Based in Nairobi, Kenya, we serve a broad range of clients across the private, public, and non-profit sectors in the region and beyond.As part of our service offering, we organize events such as leadership forums, training workshops, webinars, and other engagements designed to empower individuals and organizations. In delivering these events, we are committed to protecting the privacy and personal data of all participants in accordance with applicable data protection laws, including the Kenya Data Protection Act, 2019.
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Who Does This Policy Apply To?
This Privacy Policy applies to all individuals who register for, attend, or participate in any events organized, hosted, sponsored, or co-hosted by Career Connections Ltd.

This includes:
a) Event registrants and attendees
b) Speakers, facilitators, and panelists
c) Guests or invitees
d) Individuals participating in event-related surveys, feedback forms, or communications§
e) Virtual participants attending webinars or online sessions

By participating in our events, you acknowledge that your personal data will be collected and processed in accordance with this Policy.
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What Information Do We Collect From Participants?
We may collect and process the following categories of personal data:

Identification and Contact Information such as full name, email address, phone number, organisation and job title, phone number and national ID/passport number.

Event Registration and Participation details including events registered for or attended, attendance records, dietary or accessibility requirements (for physical events) and preferences for breakout sessions, topics or materials ·

Payment and Billing Information: including payment methods, billing details for invoicing or reimbursements.

Communication and Feedback: pre-post event surveys, event-related inquiries or correspondence, testimonials, reviews or other voluntary submissions.

Media and Recordings: including photographs, video and audio records taken during events (with your consent) and screenshots or recordings of online sessions      

Technical and Usage Data: including IP addresses, device type, login time, session duration and engagement with platform features, poll or Q&A response Policy applies to all individuals who take up CCL coaching services.
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How Do We Collect Your Information?
We collect your personal data through a variety of methods, depending on how you interact with us before, during, and after the event. These include:    

Directly from You:
a) When you register for an event through our website, email or event platform
b) When you complete forms such as registration, consent, feedback or survey forms   
c) When you communicate with us via email, phone, or in person regarding the event 
d) When you voluntarily share testimonials, comments, or participate in discussions     

Automatically through Event Tools and Platforms:
a) When you join or interact with our virtual events (e.g., login time, participation in polls, or chat)
b) Through cookies and analytics tools used on our websites or event platforms
c) Through access logs, webinar tools, or registration tracking software      

From Third Parties  
a) From event co-hosts, partner organisations, or referring parties who may submit your details on your behalf
b) From payment platforms or service providers if payment or billing is involved  
c) From publicly available sources (e.g., LinkedIn) to verify professional information where relevant
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How Do We Use Your Information?
We use the personal data collected from event participants for the following purposes:
a) To process your registration and confirm your participation
b) To communicate event details, updates, or changes
c) To manage event logistics, attendance tracking, and access control
d) To issue certificates of participation, where applicable
e) To send pre-event and post-event materials, reminders, or feedback requests
f) To respond to your inquiries or requests related to the event
g) To share recordings, presentation materials, or follow-up resources
h) To send you information about similar upcoming events or services (where permitted)
i) To use event photos, quotes, or testimonials in promotional materials (with consent)
j) To publish post-event reports or highlights on our platforms
k) To comply with legal or regulatory obligations (e.g., tax, reporting, health & safety)
l) To maintain records of event participation for audit, quality assurance, or evaluation purposes
m) To analyse participation trends and engagement metrics
n) To evaluate event effectiveness and improve future programming
o) To gather feedback to tailor our offerings to participants' needs
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What Is Our Legal Basis For Processing Your Data?
We process your personal data in accordance with the Kenya Data Protection Act, 2019, and other applicable data protection laws.
The legal bases upon which we rely include:
Consent: We process your personal data based on your explicit consent in situations such as:
‍Event registration and participation
‍Receiving marketing communications
‍Use of photographs, videos, or testimonials for promotional purposes
You may withdraw your consent at any time by contacting us.

Contractual Necessity: We process your data where it is necessary to fulfill a contract or agreement with you. For example:
‍To register you for an event
ii) To issue invoices, receipts, or participation certificates
iii) To deliver event-related materials and communications

Legitimate Interests: We may process your personal data where it is necessary for our legitimate business interests, provided these do not override your rights and freedoms. This includes:
‍Improving event quality and participant experience
ii) Sending event follow-up communications
iii) Promoting future events and services

Legal Obligation: In some cases, we are required by law to collect or retain certain data. For example:
‍Maintaining accurate accounting records
ii) Complying with health, safety, or tax regulations
iii) Responding to lawful data access requests
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Who Do We Share Your Data With?
We do not sell or rent your personal data. However, we may share your personal information with trusted third parties as necessary to facilitate your participation in our events and comply with legal obligations. These include:

Event Partners and Co-hosts: If an event is organised in collaboration with a partner or co-host, we may share relevant participant data (e.g., name, organization, contact details) with them for planning, access control, and post-event engagement—always subject to confidentiality obligations.

Service Providers: We engage third-party service providers to support event delivery. These may include event registration and ticketing platforms,webinar or virtual event hosting platforms,  IT and cloud storage service providers, payment processors, email and communication tools and catering, security, and logistics vendors (for physical events)
All such providers are contractually obligated to handle your data securely and in accordance with applicable data protection laws.

Speakers and Facilitators: With your consent, we may share participant lists (e.g., names, job titles, or submitted questions) with speakers or facilitators to tailor the content and engagement of the event.

Legal and Regulatory Disclosures: We may disclose your personal data to comply with legal, regulatory, or tax obligations, in response to lawful requests by public authoritiee and Where required by court order or government directive

Business Transfers: In the event of a reorganization, merger, acquisition, or sale of our business or assets, your personal data may be transferred to the new entity, subject to continued protection under this Policy.

Media and Publication: If you appear in event photos, videos, or testimonials and have given your consent, we may share such content in post-event reports, social media, or marketing materials.
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How Long Do We Retain Your Data?
a) We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law or legitimate business needs.

b) The specific retention periods may vary depending on the nature of the event and the type of information collected and will be guided by our Data Retention and Disposal Policy.

c) When data is no longer required, it is securely deleted or anonymised in accordance with our data retention and disposal policies.
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How Do We Safeguard Your Personal Data?
We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it from unauthorised access, loss, misuse, alteration, or disclosure. These measures include:
a) Access Controls: Limiting access to personal data to authorised personnel only, based on role and need-to-know basis. ·      
b) Data Encryption: Using encryption protocols to safeguard data during transmission and, where applicable, at rest.      
c) Secure Systems: Storing data in secure systems with firewalls, antivirus protection, and regularly updated security configurations.      
d) Staff Training: Regular training of our staff and consultants on data protection principles, confidentiality, and secure handling of personal information.    
e) Contracts with Third Parties: Ensuring that any third-party service providers we engage are bound by strict data protection and confidentiality obligations.      
f) Physical Security: Implementing physical access controls in our offices and restricting entry to secure areas.    
g) Regular Reviews: Conducting regular audits and reviews of our data protection policies, practices, and systems to ensure ongoing compliance and effectiveness.

While we take all reasonable precautions to protect your data, please note that no method of transmission over the internet or electronic storage is entirely secure. However, we remain committed to continuously improving our security practices in line with technological developments and legal requirements.
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What Rights Do You Have Over Your Data?
You have the following rights over your personal data: ·      
Right to Access: You have the right to request access to the personal data we hold about you and to obtain a copy of it

Right to Rectification: You can request that we correct or update any inaccurate or incomplete personal data.    
 
Right to Erasure: You have the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent (if applicable).

Right to Objection: You can object to the processing of your personal data based on legitimate interests, or for direct marketing purposes.    

Right to Restriction: You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest its accuracy or if you believe the processing is unlawful.

Right to Data Portability: You can request to receive your personal data in a structured, commonly used, and machine-readable format, and to transfer it to another data controller, where technically feasible.
   
Right to Withdraw Consent: If we process your data based on your consent, you have the right to withdraw your consent at any time, which will not affect the lawfulness of processing based on consent before its withdrawal.

Right to Lodge a Complaint: You have the right to lodge a complaint with the Data Commissioner if you believe your data protection rights have been violated.

To exercise any of these rights, please contact us using the contact details provided in this policy. We may need to verify your identity before processing your request.
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Changes To This Privacy Policy
We may update this policy periodically to reflect changes in our practices or legal requirements. The latest version will be available on our website
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Contact Details
If you have any questions, requests, or concerns regarding your personal data or this policy, please contact our Data Protection Officer on privacy@careerconnectionsltd.com
INTRODUCTION
Career Connections Limited (“CCL” “Company” “We” “Us” “Our”) is committed to ensuring that your personal data is collected and used lawfully and transparently.

Career Connections processes personal data relating to Assessors and/or External Associates (“You” Your”). With regard to such processing, the Company qualifies as a “Data Controller”. In this capacity, we strive to comply with the applicable Data Protection Laws in Kenya by protecting your privacy when dealing with your personal data.
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Who Are We?
Career Connections is a leading consulting firm in East Africa founded in 1997 which helps organisations hire, develop and retain the best people through expertise in executive search, talent assessments, team and leadership development, as well as executive coaching.
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Purpose of This Policy
The Company collects and processes personal data relating to Assessors and/or External Associates during the selection assessment process. We are committed to being transparent about how we collect, use that data and how we meet the data protection obligations.
This Assessors Privacy Policy:
a) sets out the types of personal data we collect about you·      
b) explains how and why we collect and use your personal data·      
c) explains how long we keep your personal data for·      
d) explains when, why and with who will we share your personal data·      
e) sets out the legal basis we have for using your personal data·      
f) explains the effect of refusing to provide the personal data collected·      
g) explains the different rights and choices you have when it comes to your personal data·     h) explains how we may contact you and how you can contact us
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Who Does This Policy Apply To?
This Assessors Privacy Policy applies to individuals and/or external associates who are involved in the assessment centres.
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Why Personal Data Do We Collect About You?
a) Contract information
b) Contact details: telephone numbers, email address and location details        
c)
Payment details
d) Assessment notes, observations on candidates behavioral and cognitive abilities
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How Do We Use Your Information?
We will use the personal data we collect about you to:  
a) Contact you to confirm availability.
b) Share a calendar invite with you as well as the assessment centre timetable, links to exercises and behavioural indicator templates.
c) Facilitate and hold the assessment centre process.
d) Enable access to the assessments, and the exercises.
e) Facilitate the scheduling of the assessment centre.
f) Familiarise on what your role is and the Candidate’s name and timeline for the assessment centre.
g) Provide you with a guide for assessing.
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What Is Our Legal Basis For Processing Your Data?
We share your personal data to the extent necessary and in compliance with Kenya Data Protection Laws with Clients, Candidates, the Company’s external associates, alumni, partners and CCL authorised team members.
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How Do We Safeguard Your Peronal Data
We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused, or disclosed, and that it is only accessed by authorized personnel for legitimate purposes. These measures include:      
a) Password protection on all laptops and devices used by employees.      
b) Non-disclosure agreements (NDAs) and/or contracts signed by Career Connections team members, restricting the sharing of your data.·      
c) Access control measures, ensuring that only authorized employees have access to specific data.    
d) Use of firewalls and other network security measures.·      
e) Regular software updates to protect against vulnerabilities.        

When sharing your data with third parties, we ensure that they adhere to strict data protection and confidentiality standards. We conduct due diligence on our third-party providers and require them to implement similar data protection measures, including secure data storage, access controls, and compliance with relevant data protection regulations. Additionally, we enter into data processing agreements with these third parties to ensure the safeguarding of your personal data.
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What Rights Do You Have Over Your Data?
You have the following rights over your personal data: ·      
Right to Access: You have the right to request access to the personal data we hold about you and to obtain a copy of it

Right to Rectification: You can request that we correct or update any inaccurate or incomplete personal data.    
 
Right to Erasure: You have the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent (if applicable).

Right to Objection: You can object to the processing of your personal data based on legitimate interests, or for direct marketing purposes.    

Right to Restriction: You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest its accuracy or if you believe the processing is unlawful.

Right to Data Portability: You can request to receive your personal data in a structured, commonly used, and machine-readable format, and to transfer it to another data controller, where technically feasible.
   
Right to Withdraw Consent: If we process your data based on your consent, you have the right to withdraw your consent at any time, which will not affect the lawfulness of processing based on consent before its withdrawal.

Right to Lodge a Complaint: You have the right to lodge a complaint with the Data Commissioner if you believe your data protection rights have been violated.

To exercise any of these rights, please contact us using the contact details provided in this policy. We may need to verify your identity before processing your request.
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What If You Do Not Provide Personal Data?
You are under no statutory or contractual obligation to provide data to the Company to facilitate the assessment centre process. However, if you do not provide the information, the Company may not be able to:·      
i) Fulfil the contractual obligations you have entered into or shall enter into.      
ii) Comply with legitimate interests such as keeping records of the process.      
iii) Fulfil the vital interests with our client.
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Changes To This Privacy Policy
This Assessors Privacy Policy shall be reviewed annually by the DPO and approved by the Board of Directors.
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Contact Details
If you have any questions, requests, or concerns regarding your personal data or this policy, please contact our Data Protection Officer on privacy@careerconnectionsltd.com