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Applicant Privacy Notice
Last Updated: September 2024
PURPOSE OF THIS NOTICE
This Applicant Privacy Notice (the “Applicant Notice”) describes how WTW plc (unless a different entity is specified) (“Willis Towers Watson,” “we,” “our” or “us”) collects and uses certain personal information relating to external job applicants and candidates (“Applicants”) for positions with us. It is intended to satisfy our applicable notice requirements under applicable data protection laws including the General Data Protection Regulation (“GDPR“), the Personal Data Protection Law (“PDPL“) and the California Consumer Privacy Act (“CCPA”).
SCOPE OF THIS NOTICE
This Applicant Notice applies to the personal information that we collect from and about Applicants, in the context of reviewing, assessing, considering, managing, storing or processing their applications or otherwise considering them for a position with us.
What is personal information?In this Applicant Notice, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
What isn’t covered by this notice.This Applicant Notice does not address or apply to our collection of personal information that is not subject to data protection laws, such as publicly available data where it is lawfully made available from a state or federal government records, or other information that is exempt under data protection laws such as the CCPA.
This Applicant Notice also does not apply to the personal information we collect from employees (which is subject to a separate privacy notice), or the personal information that we collect from customers or end users of Company’s products and services, including Applicants, in the context of their personal use of Company products and services (which is subject to our Global website Privacy Notice at https://www.willistowerswatson.com/en-US/Notices/global-website-privacy-notice).
Are our practices the same for all Applicants?The categories of personal information we collect, and our use of personal information may vary depending upon the position(s) or location, as well as the associated qualifications and responsibilities. The information in this Applicant Notice is intended to provide an overall description of our collection and use of personal information about Applicants.
CATEGORIES AND SOURCES OF PERSONAL INFORMATION COLLECTED
We will collect personal information directly from you and, our service providers (i.e., companies who are assisting us in fulfilling our contracts and carrying out our business, such as to perform mailings or to provide customer assistance) and from other third-party sources, including public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected with on social media) the following categories of personal information about Applicants:
Name, Contact Info and Other Identifiers:
identifiers including, but not limited to, a real name, alias, postal address, unique personal identifier, government identifiers including driver’s license or state identification card number, online identifiers, Internet Protocol address, email address, social security number, passport number, telephone number, or other similar identifiers.
Protected Classifications
characteristics of protected classifications under California or federal law including, but not limited to, race/ethnicity, color, sex, age, religion, philosophical beliefs, national origin, disability, genetic information, union membership, and immigration and/or citizenship status.
Usage Data:
Including, but not limited to, browsing history, search history, and information regarding an applicant’s interaction with an our websites, applications, or advertisements
Audio, Video and Other Electronic Data
audio, electronic, visual, or similar information such as CCTV footage, photographs, and interview audio recordings.
Employment History
Professional or employment-related information.
Education Information
information about education history or background, including such information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99), such as educational history, academic status, achievements, or discipline.
Profiles and Inferences:
inferences used to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes
Professional or Employment-Related Information:
application materials, hire state, job responsibilities, salary history, disciplinary or other related human resources records, performance evaluations, job end or termination date, and work authorization status.
Personal Information relating to new hire creation after offer acceptance
information that we are required to collect to comply with and fulfil our legal obligations e.g., National Identifier, Date of Birth, Citizenship, Bank Account Information, and Tax Related Information, Work Authorization Details.
Username and Password for your Talent Network Account or the Careers Site
(depending on your location, different online portals are available for applying for roles) and all information you submit through that account.
Any other information you choose to provide:
employment preferences, willingness to relocate, current salary, desired salary, photos or videos of you, awards or professional memberships.
Information relating to references
if you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to ensure that the individual agrees to you doing so prior to providing their information to us.
Sensitive personal information
in some countries we ask for information regarding the ethnic origin, religious, intellectual or political belief, gender, health data (including disability data) of our applicants for equal opportunity monitoring purposes.
Other personal information
references and background checks which may include information about your performance, skills, attitude and personal attributes provided by your references; criminal records (where relevant for certain roles), credit reports and immigration information from information available on public record or obtained through background check providers; and information about your identity, experience and suitability for a particular role from your recruitment agency, temporary staffing agency or where applicable, your current employer.
Failure to provide this information may prevent or delay your application process with us, and/or the fulfilment of our obligations as an employer. We will inform you at the time your information is collected whether certain information is compulsory and the consequences of the failure to provide such information.
PASSIVE INFORMATION COLLECTION: COOKIES AND SIMILAR TECHNOLOGY
Our Careers Site Cookie Notice contains detailed information about our use of cookies. You can manage how your preferences regarding cookies are set by this website, using our cookie preference manager.
Pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some websites to, among other things, track the actions of users of the websites (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the websites and response rates. We and our service providers also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version and internet browser type and version. This information is gathered automatically and stored in log files.
Third Party Analytics Tools. Our websites may use automated devices and applications operated by third parties (e.g., Google Analytics), which use cookies and similar technologies to collect and analyze information about use of the websites and report on activities and trends.
Opt-Out Preference Signals and “Do-Not-Track” Signals. If your browser enables the Global Privacy Control (“GPC”) when visiting our website, our website will automatically opt you out of any tracking cookies that constitute a “sale” where required by applicable privacy law. For more information about the GPC and to learn how to implement it on your browser, please click here. Please note, our website does not recognize or respond to any signal which your browser might transmit through its so-called “Do Not Track” (“DNT”) feature. If you wish to disable cookies on our websites, you should not rely on DNT browser settings. For more information about DNT signals, please click here.
PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION
Generally, we will use the above categories of personal information for the following purposes:
Recruiting, Hiring and Managing, Evaluating and Communicating with Applicants
To review, assess, recruit, consider or otherwise manage applicants, candidates and job applications, including:
- To process your application including scheduling and conducting interviews
- Identifying candidates, including by working with external recruiters
- Reviewing, assessing and verifying information provided, to conduct criminal and background checks, and to otherwise screen or evaluate Applicants’ qualifications, suitability and relevant characteristics
- Extending offers, negotiating the terms of offers, and assessing salary and compensation matters
Satisfying legal and regulatory obligations - Communicating with Applicants regarding their applications and about other similar position(s) for which they may be interested including future professional opportunities at Willis Towers Watson via Talent Network
- Maintaining Applicant personal information for future consideration
- In support of our equal opportunity employment policy and practices
- Providing insights into working at Willis Towers Watson and thought leadership content from our business
- To create your Employee Profile with Willis Towers Watson after offer acceptance
Security and Monitoring
In order to monitor and secure our resources, network, premises and assets, including:
- Monitoring for, preventing and investigating suspected or alleged misconduct or violations of work rules
- Monitoring for, preventing investigating, and responding to security and privacy incidents
- Providing and managing access to physical and technical access controls
- Monitoring activities, access and use to ensure the security and functioning of our systems and assets
- Securing our offices, premises and physical assets, including through the use of electronic access systems and video monitoring
Auditing, Accounting and Corporate Governance
Relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.
Special arrangements
If you supply sensitive personal information to us, we will process this information in accordance with the law, and only for the purposes for which you have disclosed it (for example, to make special arrangements to accommodate a disability or religious beliefs or to promote diversity in the workplace). If you would like to request a reasonable adjustment or accommodation to assist you in the application process, please do so in the relevant field during the application process.
Defending and Protecting Rights
In order to protect and defend our rights and interests and those of third parties, including to manage and respond to employee and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
Compliance with Applicable Legal Obligations
Relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, social security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance.
Human resources management
If we hire you, personal information we collect in connection with your application and Talent Network account may be incorporated into our human resources system and may be used to manage the new-hire process; any such information may become part of your employee file and may be used for other employment- related purposes. We will also incorporate your contact numbers into our emergency notification process.
Analytics
To run analytics on job descriptions and the effectiveness of job postings.
Aggregate and de-identified information. To the exent permitted by law, we may de-identify personal information and create anonymous and aggregated data sets and reports in order to assess, improve, and develop our business, products, and services, prepare benchmarking reports on our industry, and for other research, marketing and analytics purposes. When we de-identify personal information, we have implemented reasonable measures as required by law to ensure that the de-identified data cannot be associated with any individual or client. We will only maintain and use such data in a de-identified manner and do not attempt to re-identify the data, except as permitted by law.
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
Certain jurisdictions require us to have a legal basis to process your personal information. Where applicable, in most cases, we will process your personal information on one of the following legal bases:
Necessary for performance of a contract
to fulfil our contractual obligations to you in connection with your employment contract with us; and to comply with our legal obligations for example obtaining proof of your right to work status to enable us to meet relevant obligations, health and safety obligations that we must comply with as your employer or to a third party (e.g., the taxation authorities).
Legitimate interest
to meet our legitimate interests, for example to conduct the recruitment process efficiently and fairly, to manage our employees effectively. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
Consent
on occasion, we may obtain your explicit consent to collect and use certain types of personal information, for example when we are required to do so by law or if candidates ask us to pass their details to a third party for recruitment purposes. If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice.
Processing is Necessary
processing is necessary for the purposes of WTW carrying out obligations in the field of recruitment and employment which is authorized by country specific legislation. For example, in certain countries where we collect ethnicity personal information to ensure we comply with our obligations not to discriminate on the basis of race.
DISCLOSURE OF PERSONAL INFORMATION
Willis Towers Watson may share personal information with affiliates that are involved in evaluating candidates for a given position, and in particular with the employing entity that is considering your application (the name of this entity will be provided to you as part of the job description or other information provided to you about the role). These affiliates will process your personal information in accordance with this privacy notice. We will make the information available to personnel with a business need to know the information, including personnel in the recruiting, human resources and information technology departments, and in the department responsible for the position for which you are applying.
Willis Towers Watson may share personal information with our third-party service providers who provide services such as hosting and operating the Careers Site, recruiting assistance, background check processing, emergency notification services and similar services.
Willis Towers Watson also may share personal information as we believe to be necessary or appropriate to any court, regulator, law enforcement agency, government body or professional body where required under applicable law, including laws outside your country of residence, where necessary to comply with legal process or to protect or enforce the rights, privacy, safety or property of Willis Towers Watson, our clients, affiliates or third parties.
Willis Towers Watson may transfer information to a potential buyer, investor or business partner in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
DATA PROCESSING,RETENTION AND DESTRUCTION
WTW uses various processing methods on the personal information it collects, including (unless otherwise stated) organization and structuring, storage, adaptation / alteration, consultation, use and disclosure.
WTW stores personal information as needed to accomplish the purposes identified in this Notice and to meet legal requirements, including legal and compliance requirements regarding records retention, resolving disputes, and enforcing our agreements. This means that WTW may be required to maintain your information, for example, to: (1) comply with our legal or regulatory compliance needs (e.g., maintaining records of transactions you have made with us); (2) to exercise, establish or defend legal claims; and/or (3) to protect against fraudulent or abusive activity on our services and systems. For these and possibly other reasons, we may be unable to delete personal information upon request of an individual in certain cases.
We may retain different categories of information for different periods of time for the instances stated above. However, it our policy as an organization that when personal information is no longer needed or after legal authority to retain it has expired, personal information will be destroyed in accordance with applicable law and pursuant to procedures established in relation to the relevant WTW services, systems, or processes. Retention periods for records maintained by WTW, including those containing personal data are established based upon business need, statutory and regulatory record keeping requirements in the geographies where we do business, and legal obligations. If you have any further questions about our handling of personal information, please contact us at privacy@wtwco.com.
If your application is unsuccessful, we will retain your personal information in accordance with our retention policy for a period of time that enables us to:
- Check our records should you apply for another role with us.
- Contact you should another role arise that you may be interested in (unless you ask us not to do this).
- Comply with record retention requirements under the law.
- Defend or bring any existing or potential legal claims.
- Deal with any queries or complaints you may have.
When we no longer require the use of your personal information, we may anonymize it as described under “Purposes for collecting and using personal information”, or we will securely destroy it.
YOUR RIGHTS
If you register on one of our Careers Sites, you may access, review, and change your personal information stored therein on each site by logging into that Careers Site and updating your account information. The updated profile will be used as the default the next time you apply for a job using your account online. To change personal information that you have already submitted for consideration for a specific position, please update your profile and resubmit your application for that position. We encourage you to promptly update your personal information if it changes or is inaccurate.
If you register on our Talent Network, you may access, review and change your personal information stored therein by logging into the network and updating your account information.
Apart from having control over the information contained in your profile, depending on your location and any exemptions that may apply, you may have the right to:
- access your personal information;
- rectify the information we hold about you;
- erase your personal information;
- restrict our use of your personal information;
- object to our use of your personal information;
- receive your personal information in a usable electronic format and transmit it to a third party (right to data portability);
- withdraw your consent to any processing based on consent at any time; and
- lodge a complaint with us and with your local data protection authority if you believe that we have not been able to assist with your complaint or concern.
Except for California residents who should follow instructions set forth in the section below Information for California Residents, please contact us at dataaccessrequest@wtwco.com or Willis Towers Watson, 800 N Glebe Road, Arlington, VA 22203, Attn: Privacy with any such requests. In your request, please make clear what personal information you would like to access or have changed, whether you would like to have personal information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information. For your protection, we may only implement requests with respect to the information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.
SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us About This Notice” section below.
LINKS TO THIRD-PARTY WEBSITES
The Careers Site may contain links to other websites. This Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Careers Site links. The inclusion of a link on the Careers Site does not imply endorsement of the linked site or service by Willis Towers Watson or our affiliates. We encourage you to read the legal notices posted on those sites, including any privacy policies or notices.
APPLICABLE LAW AND DATA TRANSFER
The Careers Site allows you to apply for jobs world-wide, as a benefit of Willis Towers Watson’s centralized global recruitment function. This Careers Site is operated from the United States. Accordingly, any personal information you submit to the Careers Site will be collected in the United States and will be subject to U.S. laws. However, if we share your personal information with an affiliate located in another country in its capacity as a potential employer, the affiliate will handle your personal information in accordance with this Notice. Any hiring or other employment-related decisions will be made by the hiring affiliate in accordance with the laws of the country where the job will be located.
ABOUT MINORS AND CHILDREN
The Careers Site is not intended for individuals under the age of 16.
CHANGES TO THIS NOTICE
We reserve the right to amend this Notice at any time in order to address future developments of Willis Towers Watson, the Careers Site or changes in industry or legal trends. We will post the revised Notice on the Careers Site or announce the change on the home page of the Careers Site. You can determine when the Notice was revised by referring to the “Last Updated” legend on the top of this Notice. Any changes will become effective upon the posting of the revised Notice on the Careers Site, unless stated otherwise.
CONTACTING US ABOUT THIS NOTICE
If you have any questions or concerns regarding our use of personal information as described in this Applicant Notice, please contact privacy@wtwco.com.
In some countries, there is a legal requirement to provide a named individual and their contact details. These are:
| Country | Name | Contact details |
| Nigeria | Adewunmi Akinmodiro | Adewunmi.Akinmodiro@wtwco.com
Willis Towers Watson Nigeria Limited 6th Floor, Africa RE Building. Plot 1679 Karimu Kotun Street, Victoria Island Lagos, Nigeria. |
| South Africa | André Wild | Andre.Wild@wtwco.com
Towers Watson (Pty) Ltd Level 4, MontClare Place, 23 Main Road, Claremont, Cape Town, 7708 Private Bag X30, Rondebosch, 7701 |
| Pasha Karodia | Pasha.Karodia@wtwco.com
Willis South Africa (Pty) Ltd Illovo Edge, 1 Harries Road, Illovo, Johannesburg 2196 |
|
| Saudi Arabia | Paul Green | privacy@wtwco.com
AE Dubai – Business Central Tower Tower A Floor 37, Dubai Media City, PO Box 500082, Dubai, United Arab Emirates |
INFORMATION FOR CALIFORNIA RESIDENTS
In this section, we provide information for California residents as required under CCPA, which requires that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. This section does not address or apply to our handling of:
- publicly available information made lawfully available by state or federal governments
- personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA (such as protected health information that is subject to HIPAA or the California Medical Information Act, and non-public information subject to the Gramm-Leach Bliley Act or the California Financial Information Privacy Act)
- personal information we collect about employees or independent contractors at Willis Towers Watson
- personal information about individuals acting for or on behalf of another company, to the extent the information relates to our transactions with such company, products or services that we receive from or provide to such company, or associated communications or transactions (except that such individuals have the right to opt-out of any sale of their personal information and to not be subject to any discrimination for exercising such right)
Categories of personal information we collect, disclose, sell, or share. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The table above sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect, sell, share, and disclose to others for a business purpose. We collect these categories of personal information from the sources, and for the purposes described above in the main body of this privacy notice. We do not knowingly collect, sell, or share personal information which relates to individuals 16 years or younger.
The CCPA defines a “sale” as disclosing or making available to a third party Personal Information in exchange for monetary or other valuable consideration, and it defines “share” in pertinent part as disclosing personal information to a third party for cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation from third parties, we do disclose or make available personal information to third parties, in order to receive certain services or benefits from them, such as when we allow third parties to offer products or services to our employees or allow third party tags to collect information such as browsing history on our websites, in order to improve and measure our ad campaigns. Pursuant to the CCPA, the categories of Personal Information that we may “sell” or “share” as defined under the CCPA include:
- Identifiers
- Usage Data
We have “sold” and/or “shared” the categories of personal information listed above to service providers and data analytics providers in the preceding twelve months.
Rights of California residents. California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.
- Do-Not-Sell/Do Not Share: California residents have the right to opt-out of our sale or sharing of their personal information.
- Limit the Use of Sensitive Personal Information: California residents have the right in certain instances to request that we limit the use and sharing of their sensitive personal information. The CCPA defines “sensitive personal information” to include, among other things, your: social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card numbers in combination with any required security or access code, password, or credentials allowing access to an account; racial or ethnic origin, religious or philosophical beliefs, or union membership; genetic data; and biometric information (including physiological, biological, or behavioral characteristics). You can exercise your right to limit our use of sensitive personal information by clicking this link or contacting us at the toll-free number below.
- Initial Notice: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.
- Request to Delete: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law. The instructions for submitting a verifiable Request to Delete are described in the “Submitting Requests” section below.
- Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected, used, disclosed and sold about them and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information, including the:
- categories of personal information collected;
- categories of sources of personal information;
- business and/or commercial purposes for collecting and selling their personal information;
- categories of third parties with whom we have shared their personal information;
- categories of personal information that we have sold in the preceding 12 months, and for each category identified, the categories of third parties to which we sold that particular category of information; and
- categories of personal information disclosed for a business purpose in the preceding 12 months, and for each category identified, the categories of third parties to which we disclosed that particular category of personal information.
California residents may make a Request to Know up to twice every 12 months. We will respond to verifiable requests received from California residents as required by law. The instructions for submitting a verifiable Request to Know are described in the “Submitting Requests” section below.
- Request to Correct: California residents have the right to request that we correct inaccurate personal information that we maintain.
- Right to Non-Discrimination: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.
- Financial Incentives: A business may offer financial incentives for the collection, sale or deletion of California residents’ personal information, where the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent. We do not offer any such incentives at this time.
Submitting Requests
- Do-Not-Sell or Do-Not-Share (Opt-out) Requests can be submitted by accessing our cookie preference manager on our website. Requests to Know, Requests to Delete, Requests to Limit Use of Sensitive Personal Information and Requests to Correct may be submitted:
- By contacting us at 1-800-889-9288 (toll free)
- By submitting a Consumer Request through this link
We will use the following process to verify Requests to Know and Requests to Delete: We will acknowledge receipt of your Consumer Request, verify it using processes required by law, then process and respond to your request as required by law. To verify such requests, we may ask you to provide the following information:
- For a Request to Know categories of personal information which we collect, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you against information in our systems which are considered reasonably reliable for the purposes of verifying a consumer’s identity.
- For a Request to Know specific pieces of personal information or for Requests to Delete, we will verify your identity to a high degree of certainty by matching at least three pieces of personal information provided by you to personal information maintained in our systems and also by obtaining a signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request.
An authorized agent can make a request on a California residents’ behalf by providing a power of attorney valid under California law, or providing: (1) proof that the consumer authorized the agent to do so; (2) verification of their own identity with respect to a Right to Know categories, Right to Know specific pieces of personal information, or Requests to Delete which are outlined above; and (3) direct confirmation that the consumer provided the authorized agent permission to submit the request.
We will respond to verifiable requests received from California residents as required by law. For more information about our privacy practices, you may contact us as set forth above.
Consumer Requests Received in 2023. In calendar year 2023, we received and responded to consumer requests under the CCPA as set forth in the table below:
| Request Type | Number of Requests Received | Number of Requests With Which We Complied (in whole or in part) | Number of Request Denied* | Average Response Time (Number of Days) |
| Requests to Delete | 11 | 1 | 10 | 30 |
| Requests to Correct | 0 | 0 | 0 | 0 |
| Requests to Know | 7 | 3 | 4 | 30 |
| Requests to Opt-Out of the Sale/Sharing of Personal Information | 14,895 | 14,893 | 2 | 1 |
| Requests to Limit | 3 | 2 | 1 | 0 |
*This includes requests that were denied because we were unable to verify the identity of the requestor.
INFORMATION FOR SAUDI ARABIA RESIDENTS
What do we do? At WTW we provide data-driven, insight-led solutions in the areas of people, risk and capital.
Additional legal basis. The PDPL provides for several sets of legal bases for processing personal information. In addition to those listed above, and in the event that personal information is to be processed in accordance with the PDPL, we may process your personal information on the basis of your actual interests – this would be the case where the processing would serve your actual interests, but communicating with you becomes difficult, or even impossible.
Additional rights. You may have the right to claim compensation for material or moral damage if you are harmed as a result of our violation of the PDPL or its implementing regulations.
As outlined in the section entitled “Your Rights” you can complain to us and if you are not satisfied with how we handle your complaint, you can file a complaint to the Saudi Data and Artificial Intelligence Authority at this link: https://sdaia.gov.sa/en/Contact/Pages/ContactUs.aspx
