People privacy notice

Last updated March 2026
Version 2.1

1.  Who does this notice affect?

The Notice covers Our People and includes ‘you’, prospective, present and past employees, contractors, agency staff and people connected to you (such as the person you nominate to contact in an emergency), collectively “Workers”. dentsu and its group of organisations use global HR information systems (‘HRIS’) for employment management and recruitment purposes to capture and store personal data of Our People.

2. Who collects your data?

dentsu is a global media, creative and customer experience management group made up of several brands. It does business through its subsidiaries and affiliates worldwide. Your personal data is collected by the dentsu organisation that you entered into an employment contract or relationship or a contract for services with, have applied for a role with, or used to work for. Where applicable, this dentsu organisation is a data controller in relation to the personal data that is collected about you. Where this organisation has a market specific People Privacy Notice, please consult that notice. Your personal data may need to be processed by other dentsu organisations for their own independent purposes. In which case, these organisations are also data controllers of your personal data. If you have questions about which dentsu organisation is a data controller in respect of your personal data, please contact your local HR team or, where applicable, your data protection officer.

3. What is not included?

The Notice is intended to tell you how we use personal information but is not intended to create a contract with you. This Notice does not apply to the information we hold about companies or other organisations, or to other companies or organisations collecting and using your personal information. You should review their privacy policies before giving them your personal information.

4. How do we collect your personal data?

When you provide personal data about yourself and others

This is personal data that you provide to the local HR Recruitment team or enter directly into our HRIS. You may also provide us with personal data about others e.g. your dependents. We use this information for HR administration and management reasons. Examples include the administration of employment benefits or contacting your next-of-kin in the event of emergency. To comply with our legal obligations, or where we need this information to fulfil our obligations to you under an employment contract or contract for services, certain data fields in our HRIS are mandatory. Where HRIS fields are voluntary it is your choice if you wish to provide the information requested.

We may collect personal data from other organisations

We may obtain information about you from other organisations. For example, references from your previous employer(s) and background checks where permitted by applicable law. We sometimes advertise through recruitment agencies or use the services of specialist search organisations. These companies will collect your application information. You may also be asked to complete a work preference questionnaire which is used to assess your suitability for the role you have applied for, the results of which are assessed by our recruiters. If you are applying to work with us through an agency, please review their privacy notice for details of how they will handle your information.

We may collect personal data automatically from you

For example, when you use dentsu IT systems and work devices, we monitor this usage in order to provide an effective experience for you, protect the security and integrity of our systems, and safeguard confidential and personal data. This means automatically collecting information from devices accessing the dentsu network including but not limited to what applications are opened, how well the systems are running, access and login activity, file access, network traffic, and the use of removable media or external storage. We use this information to evaluate how staff use these systems, diagnose issues within the IT infrastructure, and detect and prevent security threats and policy violations. Further details are set out in Section 5 below.  

5. What kinds of personal data do we collect and how do we use it?

The personal data we collect about you depends on your circumstances, your role, the law where you are and whether you are a prospective, current or past Worker. Below you can find information we process for Workers, as well as our purposes for doing so.

RECRUITMENT

We will need to process the personal data of all prospective Workers from the moment you become a prospect or candidate for a role. This allows us to assess your suitability for the role and our business. The types of processing are as follows:

Purpose of processing your personal informationDetailGrounds for processing
Assessing suitability for the role.

We will use your personal information to assess your suitability for the role, enable shortlisting, prepare for any interviews and assessments required, and contact you to arrange, conduct, evaluate and feedback on assessments and interviews and, where successful, to make you an offer/provide you with an agreement/contract of employment. This applies to all Workers and applies whether you have made an application directly to us, have been added as a prospect or via an agency or any other third-party.

For this purpose, we will collect:

Contact details and other information to confirm your identity. This includes your name, gender, address, phone number, date of birth and email address;

Information about your employment history and skills. This includes your CV / resumes, application forms, references, records of qualifications, skills, training and other compliance requirements. This may also include records of when you contact us, emails, webchats and phone conversations; and

Information generated by us and you, through a combination of recruiting activities to further assess suitability for the role(s), such as interviews, assessment centres, assessments/tests (cognitive ability tests, skills tests, personality tests, job simulations, psychometric tests, etc). For example, you may complete a written test or we may take interview notes.

Once working at dentsu, we will also use your personal information to assess your suitability for other roles you may apply for or projects that may be assigned to you.

Legitimate Interest
Applicant administration

We will carry out pre-employment checks (where permitted by law) either using in-house resources or approved third-parties, to establish eligibility to work and other pre-Employment Checks which shall be commensurate to the risks and responsibilities of each job role such as criminal record, financial sanctions, etc and follow up references provided to us and potential other sources where necessary.

We will process and record the personal data of anyone given a job with dentsu, even if they don't turn up on their first day.

Legitimate Interest, Contractual Necessity, Legal Obligations
Talent poolIf you are unsuccessful following assessment for the role or are a prospect, we will retain your details in our talent pool for a reasonable period so that we can contact you should any further suitable roles arise. The time for which we retain your details will differ depending on where you are based. For further details please consult any notice applicable to your specific country or region. If you would like us to delete this data, please contact the data protection officer details outlined in your applicable notice or contact us at DPO@dentsu.com and we will be happy to triage your request or candidates can also request deletion of all data held in our HR system from their application login.Legitimate Interest
Reasonable adjustments

Where applicable, we will make reasonable adjustments to the recruitment process based on the accessibility requirements you make us aware of or we become aware of.

For this purpose, we may, subject to the circumstances, collect information about you to help us assess adjustments which need to be made or work restrictions which may apply. This may include your nationality, preferred language, and details of any accessibility requirements.

Legitimate Interest, Legal Obligations
Equal opportunities monitoringIn some countries we may, subject to local laws, ask you to share information about your ethnicity, disability, age, religion/belief, gender and sexual orientation. This information is used to comply with equality and diversity requirements and to help us improve our employment practices.Legal Obligations

Working for dentsu

We will use your personal information for the purposes of your contract/agreement with us, to comply with legal obligations, or where we have a legitimate interest in doing so to manage and protect our business. We will rely on legitimate interest pursued by dentsu where it is not overridden by the interests or fundamental rights and freedoms of Our People. The table below lists out the ways in which we do so.


1. To Assist You in your role
Purpose of processing your personal informationDetailGrounds for processing
Employee Administration

We will maintain and process general records necessary for the management of workers, to operate the contract/agreement of employment or contract for services between you and the dentsu organisation, and we will need to allocate and manage your duties and responsibilities and the business activities to which they relate.

Depending on where you are based, we may process and record your personal data for purposes including, but not limited to:Collecting information to facilitate your onboarding to the organisation. For example when receiving IT equipment and setting you up on our systems or sending you items to your home address if you are working remotely.

Facilitating moves within the company in the event of changes to your role, location, or manager.

Should you relocate to a different location, there are processes in place for support with visa applications, tax and relocation assistance.

Running employee surveys, new joiner or leaver surveys.

We may need to respond to reference requests that have been made for you for instance by new employers, mortgage or rental companies, etc.

For some leave requests we will need information that indicates the nature of the time off and duration so we can approve, apply correct policies and redistribute workload as needed.

In certain locations and for some roles, overtime will need to be tracked.

Where requested, we will need to process information required to help you participate in activities and programmes you are eligible for.

In some dentsu locations, we have workforce representation groups who need to be informed when workers join or leave the company.

Legitimate Interest, Contractual Necessity, Legal Obligations
Remuneration & benefits administration

This involves providing and administering remuneration, benefits (such as pension/retirement schemes, insurance, policies to benefit your health and wellbeing, etc), and recognition /incentive schemes. This may involve us passing appropriate personal information on to the relevant third-party providers so they can contact you, or you may register with them directly. We will also provide the details of any beneficiaries you nominate in case of death or other benefits to the relevant third-party.

We may use third-party suppliers for benefits and recognition systems and we’ll make sure we follow the requirements of the law and that your personal information is protected by them appropriately.

We will run pay benchmarking processes and reporting as required by law and to ensure we are rewarding our employees appropriately with equal pay.

We will process personal information in relation to staff awards, recognition schemes, and incentives to reward good performance.

We may contact you or send you gifts on special occasions such as your birthday and to recognise ‘length of service’ milestones working for us. We will do this using any personal data you provide us with (either in a HRIS or more generally) but you can always ask for this to not happen by contacting your People Leader or raising a case via Ask People Services.

Legitimate Interest, Contract Necessity, Legal Obligations
Conducting reviews and determining performance requirements.

Where applicable, we may need to conduct reviews to assess or investigate performance, capability, conduct, absence, or grievance concerns and other informal and formal HR or Legal processes, to make related management decisions and anything else required under our contract with you.

We will review and track your performance at regular intervals. Your personal information will be stored to track your progress. The ways in which your data will be used may include:

Setting objectives and goals.

Tracking progress against identified deficiencies based on specific action plans.

Tracking your competencies against your current and other roles.

Gathering feedback from managers, peers, direct reports and others in the organisation.

Managing staff rewards for fulfilling objectives / tasks.

Legitimate Interest, Contract Necessity
Processing employee work-related claimsWhere relevant, we will need to process any claim made by or involving you when a party is seeking compensation in cases of illness or injury.Legitimate Interest
Payroll management

This involves providing and administering payroll including tax and social security deductions and contributions, and any other deductions or garnishments required by law or your contract.

We will often utilise third-party suppliers for benefits and recognition systems, and we’ll make sure we follow the requirements of the law and that your personal information is protected by the appropriate technical and organisational measures.

Legitimate Interest, Contractual Necessity
Expense management

This involves reimbursing expenses where you have paid for something which is considered a genuine cost of business or providing access to corporate credit cards.

We will often utilise third-party suppliers for expense systems and credit card schemes, we’ll make sure we follow the requirements of the law and that your personal information is protected by the appropriate technical and organisational measures.

Legitimate Interest, Contractual Necessity

2. To Ensure Our Success As A Business
Purpose of processing your personal informationDetailGrounds for processing
Day to day business operations

We will process your personal data because of your day-to-day activities in your role with us at dentsu. The type of data processed will depend on the nature of your role, but can include:

Being part of group / 'all office' email distribution lists internally;

Having the capability to access staff business records such as email, Office 365, Teams and OneDrive;

Staff time management and scheduling, including timesheet recording;

Sharing contact information with clients, including for pitches;

Booking and invoicing for services;

Inviting you to and confirming your attendance at internal and external dentsu events;

Providing knowledge to a central service management system (e.g. ServiceNow) and responding to service downtime;

Logging IT Service Desk tickets with internal system providers, which includes support to: (i) permit internal or external IT support to remotely operate or physically repair staff systems as necessary to fix / manage requests raised by you (only when you have granted access via screenshare or camera); and, (ii) provision of AI service desk chatbot to assist with triaging service tickets;

Tracking intranet usage: You will be searchable on the intranet, and your information will appear on pages where you have created or contributed content;

Meeting room and desk booking systems.

Legitimate Interest, Contractual Necessity
Business management and planning

Your personal data may be stored to allow dentsu to manage its business operations and plan appropriately for the future.

This will include resource planning, project planning, staff cost management, resource allocation, client profitability analysis and timesheet compliance. Managers are required to assess their direct reports to assess Potential Level, Retention Risk and Impact of Loss. Your information will be processed for this on an ongoing basis.

Legitimate Interest
Accounting & auditing

This includes managing forecasting, budget / account management and planning for the future.

From time to time, we will disclose your personal data to third-party service providers (e.g. Microsoft Dynamics 365) to assist in our accounting and auditing processes.

Legitimate Interest, Contractual Necessity
Preventing and detecting crimeWe use your information to prevent and detect unlawful activity, including IT and building access rights and security monitoring, use of CCTV, fraud detection and prevention measures.Legal Obligations, Legitimate Interest
Network and information security

We have systems and processes in place to protect our data, IT network, computer systems, and electronic communications from security threats. Your personal data may be processed to support these efforts in the following ways:

  • Authenticating legitimate users and logging access to corporate systems, applications, and data, including login times, file access, sharing, and download activity;
  • Analysing network traffic to detect and prevent unauthorised access, data exfiltration, or other security threats;
  • Deploying endpoint detection and response tools on dentsu-managed devices to identify malware, suspicious activity, or policy violations;
  • Monitoring the use of removable media, cloud storage services, and external file transfers, and restricting where corporate data can be stored;
  • Applying data security posture management solutions to identify and remediate system vulnerabilities and to ensure the application of relevant dentsu data governance rules and policies;
  • Using data loss prevention tools to identify potential risks and prevent the unauthorised transmission of sensitive or confidential information;
  • Training and testing staff in phishing awareness;
  • Setting up IT alerts and contacting you in the event of a security incident; and
  • Conducting audits and investigations where there is reasonable suspicion of misuse, policy breach, or unlawful activity.

To further enhance security, we have deployed a secure corporate browser for dentsu-managed devices and for dentsu corporate apps on personal devices. This system monitors user browsing activity to protect against malicious websites, threats, malware and policy violations, capturing and storing all browser-related traffic, including (but not limited to) websites visited, data transfers, IP addresses, usernames, dates and times of visits to websites, and dentsu email addresses. We also deploy tools which capture and process data regarding the reliability of dentsu devices and systems and to provide access for users to secure web sessions, AI services and password management functionality and to identify issues requiring further diagnostics and remediation by monitoring various technical parameters of end-user devices, with a view to undertaking analytics on device performance in real time.

Legal Obligations, Legitimate Interest
Support internal administration with our affiliated entities.This can include planning, due diligence and implementation in relation to a commercial transaction or service transfer that impacts your relationship with dentsu. For example, mergers and acquisitions or a transfer of your employment under automatic transfer rules.Legitimate Interest
Data analytics and reporting

We do this to review and better understand employee retention and attrition rates, and to understand the success of our systems / programmes. This helps inform our business decisions and we will often use the assistance of external parties to do this.

Your information may be gathered for business operational and reporting documentation such as the preparation of annual reports, which may use photographic images and graphs, and staff engagement or benchmark questionnaires. Your data, if used, will normally be anonymised so that you would not be personally identified.

We will also run data mining to assess the success of our systems and analyse how we can help you work more efficiently.

Legitimate Interest

4. To Resolve Disputes
Purpose of processing your personal informationDetailGrounds for processing
Gathering evidence for disciplinary action or termination.

Sometimes we may need to gather personal data in relation to any allegations, complaints, investigations and disciplinary processes that occur during your time working at dentsu, whatever your role in the process.

This can include "whistle blowing or speak up now" reports from employees and are handled through third-party services.

Evidence in all cases will need to be gathered and recorded for the duration of any investigation.

We may also need to manage litigation proceedings on behalf of dentsu. Your data may be processed where required.

Legitimate Interest
Monitoring of work communicationsIn accordance with applicable laws, we reserve the right to monitor and scan electronic communications sent using the accounts, network and devices we provide to you for work purposes. This includes email, instant messaging, video conferencing, and other communication tools provided by dentsu. Monitoring may be conducted to ensure that dentsu IT resources are being used in compliance with the law and are in line with dentsu policies, to protect the security and integrity of our systems and data, and to support investigations into suspected misconduct, policy breaches or unlawful activities. You can learn more information about using dentsu IT resources in our Acceptable Use Policy on dentsu dot.Legitimate Interest, Legal Obligation

Leaving dentsu

After you end your role with us, we may need to retain your personal information to fulfil certain business obligations for the following purposes:

Purpose of processing your personal informationDetailGrounds for processing
Employee administration

When you leave dentsu, we run certain processes involving your personal data to understand why you left us, to help run our business or to support a legal obligation we have.

When you leave, we may conduct an exit interview and ask you to partake in a leaver’s survey.

Your data will be used when we are preparing for your departure, for example when you are returning IT equipment or corporate credit cards. This may involve the use of your home address if you are working remotely.

We will also retain information to manage and administer your pension and other related legal obligations.

Legitimate Interest, Contractual Necessity, Legal Obligations
Business management and planningSometimes we need to deal with claims or disputes involving you or others. This could include an accident at work. We do this because we have a legal obligation to provide the information, or it is in our interests to bring or defend a claim.Legitimate Interest
Business management and planning

After you leave, we will retain certain information to understand and evidence decision making in your role and maintain knowledge within the business; for example, this may include your handover notes or emails you have sent. We do this because it is in our interests to use this information to help run our business, or it may be to support a legal obligation we have.

We may also ask if you’d like to opt in to our alumni marketing programme whereby you can receive communications about dentsu and information about new job openings.

Legitimate Interest, Contractual Necessity
Complying with applicable lawWhere required, we may need to use your personal information to comply with our obligations to third parties in connection with your employment, such as tax authorities and professional bodies.Legal Obligations, Legitimate Interest
Equal opportunities monitoringWhere required or permitted by applicable law, we run monitoring programmes to ensure equality of opportunity and diversity with regard to personal characteristics protected under local anti-discrimination laws.Legal Obligations, Legitimate Interest


6. Sharing your information

Across dentsu:

dentsu is a global organisation. To ensure effective and efficient services and communications throughout the group, your personal data may be shared with other dentsu organisations, for example with our group companies in Japan and the USA.

The following people and teams within dentsu may be granted, on a need-to-know basis, access to your personal data:

  • Local, regional and global HR managers and HR team members;
  • Local, regional and executive management responsible for managing or making decisions in connection with your relationship with dentsu, or when involved in an HR process concerning your relationship with dentsu; system administrators; and
  • Where necessary for the performance of specific tasks or system maintenance, teams such as the Finance, Legal & Compliance, Technology & Security and HR teams.

Basic personal data, such as your name, location, job title, contact information, any published skills and experience profile, as well as any photo that you upload to the HRIS, may be accessible to other employees to facilitate standard business operations.

Outside dentsu:

Your personal data may be also shared with organisations outside of the dentsu group. To help you understand who these organisations are, here is a non-exhaustive list:

  • Third-party suppliers: Organisations (and their sub-contractors) that provide us with technology solutions and/or support such as the organisations that have been engaged to host, support and otherwise maintain systems we use to process your personal information. This could also include organisations that provide systems which interconnect with the HRIS or are used more generally. Examples include expense management software, payroll and benefits systems, IT servicing technology and systems (including service desk support provision and local on-site engineer resources) and many more. Where we use a third-party service provider we’ll make sure we follow the requirements of the law and that your personal information is protected by the appropriate technical and organisational measures.
  • dentsu’s professional advisers: We may need to share your information with professional advisers including but not limited to IT administrators, auditors, consultants, payroll providers, external lawyers, administrators of dentsu’s benefits programmes.
  • Insurance providers: We may also need to share your information with insurance providers in relation to our insurance policies.
  • Clients: We may share your information with our clients where necessary to manage and deliver services to them.
  • Public authorities: We may share your information with public authorities to comply with lawful requests (including without limitation to meet national security or law enforcement requirements) or where otherwise required, whether within or outside your country. We only share your personal information in accordance with applicable laws and have strong internal oversight of what we do and take expert advice to inform our approach.

7. Protecting your information and how long we keep it for

How do we protect your personal information?

We have implemented appropriate technical and organisational measures to protect your personal information. These include but are not limited to, physical building controls, device and file encryption and ID verification. Where we transfer your personal information to third-party provider we only do so where we have the appropriate safeguards in place to protect your personal data.

How long do we keep your personal information?

We keep your personal data for as long as it is required to fulfil such purpose(s) for which it was collected. This will usually be the period of your employment or contract for services, or as otherwise set out in the context of prospective employees or other, with the dentsu organisation plus the length of any applicable statutory limitation period once that employment or contract period has ended. For example, data such as tax and pensions information, may need to be kept for longer. Otherwise we will delete or anonymise it so that you cannot be identified and it can no longer be associated with you.

Further information about our data retention policies and requirements for different categories of data we use across our network is available here

8. Your rights

Depending on the applicable privacy law of the market you are in, you may have several rights in relation to your Personal Data, including:

Objecting to our processing of your Personal Data. Where we rely on legitimate interest (or those of a third-party) and if you feel it impacts on your fundamental rights and freedoms, you can object to our processing. You can object at any time, and we shall stop processing the data you have objected to, unless we can show legitimate grounds to continue. 

Accessing your Personal Data. We may be required to provide you with information we hold about you upon your request, including a description and copy of the Personal Data and why we are processing it, unless a lawful exception applies.

Requesting the provision of your Personal Data to a third party. You may ask us to provide you or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. This right only applies to Personal Data you have provided to us; and if you have consented to our use or where we used the Personal Data to perform a contract with you. 

Requesting erasure (deletion) of your Personal Data.  You may ask us to delete your data where you think we no longer require it. Note, we may be required to retain certain Personal Data by law and/or for our own legitimate business purpose. But when we do so, we will inform you.

Requesting correction or updating of your Personal Data. This enables you to have any incomplete or inaccurate Personal Data we hold about you corrected. 

Requesting the restriction of our processing of your Personal Data. In some situations and only in some jurisdictions you can request a restriction to our processing. If you request this, we can continue to store your Personal Data but are restricted from processing it while the restriction is in place.

Withdrawing your consent. Where you have consented to our processing of your Personal Data, you can withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of what we have done with your Personal Data before you withdrew consent or affect our right to continue with our collection, use or disclosure of your Personal Data where such collection, use or disclosure of Personal Data is permitted under applicable laws without consent.

Making a Complaint. We will do our best to resolve any complaint. However, if you feel we have not resolved your complaint, or if you wish to reach out to them directly, you can complain to your local data protection authority. For example, in the UK, the local data protection authority is the UK Information Commissioner's Office. If you have any questions about who your local authority is, please contact us and we can provide the relevant information.

If you exercise the rights above, the request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide adequate information that we can reasonably verify that you are the person about whom we collected the personal information (including information that enables us to verify the identifying information we possibly maintain about you).

We will respond to requests within the required timeframes. If we need extra time to respond, we will let you know why, and how long we require, in writing. To protect your Personal Data, we will only honour requests if we have been able to verify your identity or authority to make the request and confirm the Personal Data relates to you. The method used to verify your identity will depend on the type, sensitivity and value of the information, including the risk of harm to you posed by any access or deletion. Verification will usually be performed by matching the identifying information provided by you to the personal information that we already have.

Note that if you are in a market where these rights do not exist, we reserve the right to deny your request.

9. Use of Artificial Intelligence and emerging technologies when processing your personal data

dentsu may use artificial intelligence ("AI"), including but not limited to genAI, agentic AI, and machine learning, and other emerging technologies to support our employment, HR, administrative, and operational functions. These technologies may be deployed to assist with many of the processing activities described throughout this Notice, including recruitment, HR administration, performance management, learning and development, workforce planning, business operations, and IT security. Where we engage third-party suppliers to provide AI-powered services that process your personal data, we ensure that appropriate contractual safeguards are in place and that such providers comply with applicable data protection requirements.

dentsu does not use AI or automated decision-making systems to make decisions about individuals that produce legal effects concerning them or similarly significantly affect them without meaningful human review. Where AI tools are used to support decision-making processes that may have a significant impact on you, a qualified human decision-maker will always review the AI-generated output and make the final determination. We have implemented internal safeguards to ensure that all personal data processed using AI is handled securely and in accordance with applicable local laws.

10. Third Party Links, Plugins, and Integrations

dentsu may use third party websites, applications, plugins, widgets, or integrations (“Third Party Tools”) to support our recruitment, HR, administrative, and operational functions. These Third Party Tools operate independently from us and may collect, use, or share information about you in accordance with their own privacy practices. When you interact with such features – whether by accessing an external link, using an embedded tool, or choosing to authenticate through a third party provider (e.g., social sign-ons) – the relevant third party may process certain information about you. dentsu is not responsible for the privacy, security, or content of third party websites or tools, and this Privacy Notice does not apply to their processing activities.

11. Updates

Our Notice might change from time to time. We’ll notify you about any changes to the Notice by posting on our website, internal intranet or contacting you directly.

12. Contact Us

If you have any questions about this Notice, our approach to privacy or you would like to exercise any of the rights mentioned in this Notice you can contact our Data Protection Officer in any of the following ways:

Address: Data Protection Officer, dentsu international, Regent’s Place, 10 Triton Street, Regent’s Place, London, NW1 3BF 

Email: DPO@dentsu.com  [Or using the information of your local DPO included in the section below].

13. Glossary

dentsu organisationThe specific dentsu entity that entered into an employment contract or relationship or a contract for services with you.
Data controllerThe natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. This will be the dentsu organisation that entered into an employment contract or contract for services with you. It may also include other dentsu organisations that need to process your personal data for their own purposes.
Other dentsu organisationThe parents, affiliates, and/or subsidiaries of the dentsu organisation described above.
Processing (or Processed)Any operation which is performed on personal data - such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Personal Data

Personal Data means information that identifies you as an individual, or is capable of doing so. Any information relating to an identified or identifiable person. An identifiable person is someone who can be identified, directly or indirectly, by reference to details such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

Personal Data includes Special Category Data, being more sensitive personal data such as information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, and data concerning sex life or sexual orientation.

Personal Data also includes Criminal Offence Data, being personal data relating to criminal convictions and offences or related security measures.

Additional market information

We provide additional information about our controllers and data protection officers (as applicable), the privacy, collection, and use of personal information data subjects of dentsu located in certain markets.

New Zealand

The ‘grounds for processing’ set out in the Privacy Notice are not necessarily grounds for processing under New Zealand privacy laws.