Privacy Notice for the Rewards Solutions & Performance Solutions Practices at Aon

The Rewards Solutions & Performance Solutions practices at Aon (which deliver products and services under the Aon, McLagan, Radford, New Bridge Street, Scorpio Partnership and/or Wards names - collectively known as the “Rewards Solutions & Performance Solutions Practices”), are professional services units within Aon providing a broad range of compensation benchmarking, performance benchmarking, analytics and advisory services.

The Rewards Solutions & Performance Practices are committed to protecting your privacy. This commitment reflects the value we place on earning and keeping the trust of our clients, business partners, and others who share their personal information with us.

What does this Privacy Notice do?

This Privacy Notice ("Notice") explains the information processing practices within the Rewards Solutions & Performance Solutions Practices. It applies to any personal information you provide to us and any personal information we collect from other sources.
 
This Notice is a statement of our practices and of your rights regarding your personal information.
 
This is not a contractual document, and it does not create any rights or obligations on either party, beyond those which already exist under data protection laws.
 
This Notice does not apply to your use of third party sites linked to this website.
 
If you have a disability and require an alternative format to this Notice, please email us at: privacy@aon.com so that we may provide you with a more suitable format.

Who is responsible for your personal information?

Throughout this Notice, "Rewards Solutions & Performance Solutions Practices" refers to Aon plc, including its affiliated companies and subsidiaries (also referred to as "we", "us", or "our"). Unless otherwise indicated, the Aon entity responsible for your personal information (and the controller for the purposes of data protection laws) will be the Aon entity that originally collects information from or about you. You can contact us using the contact details below for more information about this.

When and how do we collect your personal information?

We collect personal information at the following times and in the following ways:

  • when you inquire about the products and/or services we offer;
  • when you procure products and/or services from us and/or become a client;  
  • when we perform services for our clients, including, but not limited to, collecting compensation survey inputs and making consulting-related data requests;
  • when you register with or use any of our websites or mobile applications;
  • when you visit any of our office sites or register for/attend any of our events;
  • when we source personal information from other Aon-affiliated companies and subsidiaries and third parties;  
  • when you engage with us over social media; or
  • when you contact us with a complaint or a request.

What personal information do we collect?

In general, we collect personal information about you that you provide to us, that we receive from other Aon-affiliated companies and subsidiaries and third parties or that we indirectly collect or infer about your activities or usage of our websites, mobile application or products and services. The personal information we collect about you varies depending upon the nature of the services and/or products and our interactions with you.

Personal information you provide to us

When you request products and/or services from us, we ask that you provide accurate and necessary information that enables us to respond to your request. When you provide personal information to us, we use it for the purposes for which it was provided to us as stated at the point of collection or as obvious from the context of collection (for example producing compensation survey results and consulting deliverables, providing a product price quote, or creating a profile on our websites or mobile applications).

We may collect personal information such as:

  • demographic information related to the business performance and operations of our client companies, including, but not limited to, financial metrics, global headcount, global employee distribution and/or locations, and organizational structures/reporting relationships;
  • demographic information related to the employees of our client companies, including, but not limited to, job titles, job roles, age, gender and individual performance levels;
  • demographic information such as basic personal details, education & professional experience & affiliations, family, lifestyle & social circumstances, basic HR details and employee performance which provides our clients with an outsourced service;  
  • compensation information related to the operations of our client companies, including, but not limited to, plan documents, pay structures/ranges and plan design, eligibility and metrics;
  • Compensation information related to the employees of our client companies, including, but not limited to, base salaries, allowances, bonuses, and long-term cash and equity incentives; or
  • other relevant information that may be needed to perform our work, such as occupation, language, zip code, area code, location, and the time zone.

We will not collect any sensitive personal information unless this is strictly required. Sensitive personal information includes a number of types of information relating to: race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life.

Where you provide personal information to us about third party individuals, where appropriate, you should provide these individuals with a copy of this Notice or ensure they are otherwise made aware of how their personal information will be used by us.

Information we collect over our Rewards Solutions & Performance Solutions Practices websites, mobile applications and social media

We may ask you for personal information, such as name and contact information, when you register for events, request services, manage accounts, access various content and features or directly visit our websites. (For purposes of this Notice, "website" includes our mobile applications.)

In some instances, we automatically collect certain types of information when you visit our websites and through e-mails that we may exchange. Automated technologies may include the use of web server logs to collect IP addresses, "cookies" and web beacons. Further information about our use of cookies can be found in our Cookie Notice.

Social Media

You can engage with us through social media sites or through features such as plug-ins or applications on our websites that integrate with social media sites. You may also choose to link your account with us to third party social media sites. When you link your account or engage with us on or through third party social media sites, plug-ins, or applications, you may allow us to have ongoing access to certain information from your social media account (e.g., name, e-mail address, photo, gender, birthday, the posts or the 'likes' you make).

Content you post

If you post information when you interact with our websites through social media sites, plug-ins or other applications, depending on your privacy settings, this information may become public on the Internet. You can control what information you share through privacy settings available on some social media sites. For more information about how you can customize your privacy settings and how third party social media sites handle your personal information, please refer to their privacy help guides, privacy notices and terms of use.

Mobile devices

If you access our websites on your mobile telephone or mobile device, we may also collect your unique device identifier and mobile device IP address, as well as information about your device's operating system, mobile carrier and your location information. We may also ask you to consent to providing your mobile phone number (for example, so that we can send you push notifications).

Categories of personal information we may collect, disclose, and “sell”

The types and categories of personal information we collect about you depends on the nature of the services and/or products we provide to you and our interactions with you. Additionally, we may disclose personal information to third parties and service providers for the purposes identified below.

In general, we do not disclose or share personal information to third parties in exchange for their monetary payment to us. However, certain laws including the California Consumer Privacy Act ("CCPA") define "sale" broadly to include disclosing or making available personal information to third parties in exchange for monetary payment or some other thing of value. For purposes of the CCPA, we may disclose or make available personal information in order to receive some benefit or value (i.e., a "sale" under the CCPA).

The categories of personal information we may collect, disclose and "sell" are as follows:

Categories of personal information Specific types of
personal information
Is this personal information collected? Is this personal information disclosed for business purposes? Is this personal information sold?
Name, contact and identifiers  Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Yes Yes No
Customer Records Paper and electronic customer records containing personal information, such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Yes Yes No
Protected Classifications Characteristics of protected classifications under California or federal law.  Yes Yes No
Purchase history and tendencies Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies No No No
Biometric Information Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns  or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information No No No
Usage data Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement. Yes No No
Geolocation Data Precise geographic location information about a particular individual or device. 
Eg Google Analytics
No No No
Audio/Visual Data Audio, electronic, visual, thermal, olfactory, or similar information Yes No No
Employment History Professional or employment-related information Yes Yes No
Educational Information Information about education-related history or background Yes Yes No
Profiles and Inferences Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes Yes No No
“Sensitive data” Information relating to race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life. Yes No No

How do we use your personal information?

The following is a summary of the purposes for which we use personal information together with the legal basis for collecting such information.

Performing services for our clients

We process personal information which our clients provide to us to perform our Rewards Solutions & Performance Solutions Practices services, analytics, and advisory services. This may impact you, for example, where you are the employee or prospective employee of our client. The precise purposes for which your personal information is processed will be determined by the scope and specification of our client engagement, and by applicable laws, regulatory guidance and professional standards. It is the obligation of our client to ensure that you understand that your personal information will be disclosed to the Rewards Solutions & Performance Solutions Practices at Aon as outlined in this Notice.

Administering our client engagements

We process personal information about our clients and the employees of our clients to:

  • carry out "Know Your Client" checks and screenings prior to starting a new engagement;
  • carry out client communications, services, billing, and administration;
  • complete client projects;
  • secure client feedback;
  • deal with client complaints and requests;
  • create marketing materials such as white papers, case studies, and social media content; or
  • contacting and marketing to our clients.

We also process personal information about our clients/prospective clients and employees of our clients/prospective clients to:

  • contact our prospects and clients in relation to current, future and proposed engagements;
  • send our prospects and clients newsletters, know-how, promotional material and other marketing communications; or  
  • invite our prospects and clients to events (and arrange and administer those events).

Conducting data analytics

We are an innovative business, which relies on developing sophisticated products and services by drawing on our experience from prior engagements. We are not concerned with an analysis of identifiable individuals, and we take steps to ensure that your rights and the legitimacy of our activities are ensured through the use of aggregated or otherwise de-identified data.

The categories of information we use to conduct data analytics include:

  • Basic personal details, education & professional experience & affiliations, family, lifestyle & social circumstances, basic HR details and employee performance.
  • Job titles, job roles, age, gender and individual performance levels.
  • Compensation information related to the employees of our client companies, including, but not limited to, base salaries, allowances, bonuses, and long-term cash and equity incentives
  • Other relevant information that may be needed to perform our work, such as occupation, language, zip code, area code, location, and the time zone

If we wish to use your personal information for a purpose which is not compatible with the purpose for which it was collected for, we will generally request your consent. In all cases, we balance our legal use of your personal information with your interests, rights, and freedoms in accordance with applicable laws and regulations to make sure that your personal information is not subject to unnecessary risk.

Legal basis

All processing (i.e. use) of your personal information is justified by a "lawful basis" for processing. In the majority of cases, processing will be justified on the basis that:

  • the processing is necessary for the performance of a contract to which you are a party, or to take steps (at your request) to enter into a contract (e.g. where we help an employer to fulfil an obligation to you under an employment contract in relation to the delivery of employee benefits);
  • the processing is necessary for us to comply with a relevant legal obligation (e.g. where we are required to collect certain information about our clients for tax or accounting purposes, or where we are required to make disclosures to courts or regulators); or
  • the processing is in our legitimate commercial interests, subject to your interests and fundamental rights (e.g. where we use personal information provided to us by our clients to deliver our services, and that processing is not necessary in relation to a contract to which you are a party).

In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required to obtain your prior consent in order to send you marketing communications.

Before collecting and/or using any special categories of personal information, or criminal record data, we will establish a lawful basis which will allow us to use that information. This basis will typically be:

  • your consent;
  • establishment, exercise or defence by us or third parties of legal claims; or
  • specific exemption provided for under local laws countries.

We do not directly provide services and/or products to children, and we do not knowingly collect personal information from children.

How long do we retain your personal information?

How long we retain your personal information depends on the purpose for which it was obtained and its nature. We will keep your personal information for no more than the time required to fulfil the purposes described in this Notice unless a longer retention period is permitted by applicable laws.
 
In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
 
We have implemented appropriate measures to ensure your personal information is securely destroyed in a timely and consistent manner when no longer required.

Do we disclose your personal information?

Within Aon

We may share your personal information with other Aon affiliates companies and subsidiaries to serve you, including for the purposes listed above.

We do not rent, sell or otherwise disclose personal information with unaffiliated third parties for their own marketing use. We do not share your personal information with third parties except in the following circumstances outlined below.

Authorized service providers

We may disclose your personal information to service providers we have retained (as processors) to perform services on our behalf (either in relation to services performed for our clients, or information which we use for its own purposes, such as marketing). These service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. These activities could include any of the processing activities that we carry out as described in the above section, ‘How we use your personal information.’

Examples include:

  • IT service providers who manage our IT and back office systems and telecommunications networks;
  • marketing automation providers;
  • contact centre providers;
  • translation agencies; and
  • companies who have surveying technology or other market research capabilities and collect insight on our behalf.

These third parties appropriately safeguard your personal information, and their activities are limited to the purposes for which your personal information was provided.

Legal requirements and business transfers

We may disclose personal information (i) if we are required to do so by law, legal process, statute, rule, regulation, or professional standard, or to respond to a subpoena, search warrant, or other legal request. (ii) in response to law enforcement authority or other government official requests, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iv) in connection with an investigation of suspected or actual illegal activity, (v) in the event that we are subject to a merger or acquisition to the new owner of the business, (vi)  in connection with  company audits or (vii) in order to investigate a complaint or security threat.

Do we transfer your personal information across geographies?

We are a global organization and may transfer certain personal information across geographical borders to our, authorized service providers or business partners in other countries working on our behalf in accordance with applicable laws. These third parties may be based locally, or they may be overseas some of which have not been determined by the European Commission to have an adequate level of data protection.

When we do, we use a variety of legal mechanisms to help ensure your rights and protections travel with your personal information:

  • we ensure transfers within are covered by agreements based on the European Commission's standard contractual clauses, which contractually oblige the concerned parties to ensure that personal information receives an adequate and consistent level of protection wherever it resides within;
  • where we transfer your personal information outside of your jurisdiction to third parties who help provide our products and services, we obtain contractual  commitments from them to protect your personal information such us, the European Commission's standard contractual clauses or the well-recognized certification schemes like the EU - US Privacy Shield for the protection of personal information transferred from within the European Union to the United States; or
  • where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information are disclosed.

Examples of countries we transfer personal information to include, but are not limited to, the United States of America, the United Kingdom, Ireland, Singapore, India and the Philippines.

If you would like further information about whether your information will be disclosed to overseas recipients, please contact us as noted below. You also have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments, which may be redacted for reasons of commercial confidentiality) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

Do we have security measures in place to protect your information?

The security of your personal information is important to us and we have implemented reasonable physical, technical and administrative security standards to protect personal information from loss, misuse, alteration or destruction. We protect your personal information against unauthorized access, use or disclosure, using security technologies and procedures, such as encryption and limited access. Only authorized individuals access your personal information, and they receive training about the importance of protecting personal information.

Our service providers and business partners are contractually bound to maintain the confidentiality of personal information and may not use the information for any unauthorized purposes.

What choices do you have about your personal information?

We offer certain choices about how we communicate with our clients and what personal information we obtain about them and share with others. When you provide us with personal details, if we intend to use those details for marketing purposes, we will provide you with the option of whether you wish to receive promotional email, SMS messages, telephone calls and postal mail from us. At any time, you may opt out from receiving interest-based advertising from us by visiting the opt-out page on our websites or by contacting us using the details below.

You may also choose not to receive marketing communications from us by clicking on the unsubscribe link or other instructions in our marketing emails or contacting us as noted below.

How can you update your communication preferences?

We take reasonable steps to provide you with communication about your personal information. You can update your communication preferences in the following ways.

Profile

If you have created a profile or account on one of our websites, you can update your contact information after you log into your account.

Newsletters

If you request electronic communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in the communication.

Mobile devices

If you previously chose to receive push notifications on your mobile device from us but no longer wish to receive them, you can manage your preferences either through your device or the application settings. If you no longer wish to have any information collected by the mobile application, you may uninstall the application by using the uninstall process available on your mobile device.

Email

Contact us by e-mail or postal address as noted below. Please include your current contact information, the information you are interested in accessing and your requested changes.

If we do not provide you with access, we will provide you with the reason for refusal and inform you of any exceptions relied upon.

Other rights regarding your personal information and how to exercise these rights

Data protection laws vary among countries, with some providing more protection than others. Subject to certain exemptions, and in some cases, particularly if you reside in a jurisdiction with applicable data protection laws, dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information.

Right to access

You may have right to access personal information which we hold about you. If you have created a profile, you can access that information by visiting your account.

Right to rectification

You may have a right to request us to correct your personal information where it is inaccurate or out of date.

Right to be forgotten (Right to erasure)

You may have the right under certain circumstances to have your personal information erased. Your information can only be erased if your personal information is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the personal information.

Right to restrict processing

You may have the right to restrict the processing of your personal information, but only where:

  • its accuracy is contested, to allow us to verify its accuracy;
  • the processing is unlawful, but you do not want it erased;
  • it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
  • you have exercised the right to object, and verification of overriding grounds is pending.

Right to data portability

You may have the right to data portability, which requires us to provide personal information to you or another company (as controller) in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party.

Right to object to processing

You may have the right to object the processing of your personal information at any time, but only where that processing has our legitimate interests as its legal basis. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
 
We do not sell your personal information without your prior consent.

International transfers

As noted above, you can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Economic Area.

If applicable, how do you exercise these rights?

You can exercise your rights by contacting us at privacy@aon.com or by calling +1.877.384.4276 (US toll free). Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

To verify your identity, please be prepared to submit the following information: your name, zip or postal code, date of birth, and any other information you have previously provided to Aon. We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. 
 
You may also be able to designate an authorized agent to make a request regarding these rights on your behalf.  If you would like to do so, please have your authorized agent use the contact email or number above and state within their request they are your authorized agent. If needed, Aon will inform the authorized agent of any additional verification data needed to process such request at that time.
 
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
 
Discrimination: If consumers exercise their rights under CCPA, businesses may not discriminate against them, such as by denying or providing a different level or quality of goods or services or charging or suggesting that a business will charge different prices or rates or impose penalties (unless doing so is reasonably related to the value received from the consumer personal information).
 
Disclosure of incentives: If businesses offer any financial incentives for the collection, sale or deletion of their personal information, consumers have the rights to be notified of any financial incentives offers and their material terms, as well as the to not be opted into such offers without prior informed opt-in consent and to be able to opt-out of such offers at any time. Businesses may not offer unjust, unreasonable, coercive or usurious financial incentives. We do not offer any incentives at this time.

Complaints

If you wish to make a complaint about the way we use your personal information you should raise this with us by contacting us in the first instance:

Aon Global Privacy Office
Aon plc
200 E. Randolph
Chicago
Illinois 60601
Email: privacy@aon.com.
Telephone: +1.877.384.4276 (US toll free)

However, if you are not satisfied with the way we have handled your complaint you have the right to raise the matter with the relevant data protection regulator.

Contact Us

If you have any questions about the content of this Notice or the rights conferred to you under applicable data protection laws, please contact us at the following address:

Aon Global Privacy Office
Aon plc
200 E. Randolph
Chicago
Illinois 60601
Email: privacy@aon.com.
Telephone: +1.877.384.4276 (US toll free)

Changes to this Notice

We may update this Notice from time to time. When we do, we will post the current version on this site, and we will revise the version date located at the bottom of this page.

We encourage you to periodically review this Notice so that you will be aware of our privacy practices.

This Notice was last updated on December 5th, 2019.