This Privacy Statement explains how Connor Consulting Corporation (CCC) collects and uses Personal Information and describes the rights you have with respect to your Personal Data and interactions with Connor.
In this statement, “Connor”, “CCC,” “our”, “we” or “us”, refers to the global organization of the member firms of Connor Consulting Corporation, each of which is a separate legal entity, or refers to one or more of those member firms.
At Connor Consulting Group we are committed to protecting your privacy. This Privacy Statement covers the collection, use and sharing of Personal Information collected from individuals and/or third parties that interact with Connor. Additionally, this statement provides information on the rights of individuals with respect to their Personal Information. Connor may use Personal Information provided to us for any of the purposes described in the relevant sections of this Privacy Statement or as otherwise stated at the point of collection.
The following Privacy Statement applies to information collected at www.connor-consulting.com and Connor-owned or operated online services (jointly “Sites”). In addition, this statement applies to information that may be gathered via email, phone calls, in person interactions, web meetings or other means.
By accessing and continuing to use this Site you acknowledge that you have read and that you agree to the practices described herein. For information related to the processing of Personal Information about our job applicants, please see our Recruitment Privacy Notice.
“Connor Consulting Group” (and “CCC”, “we”, “us”) refers to Connor Consulting Corp. with a principal place of business located at 300 Brannan St # 511 San Francisco, CA 94107.1. Information Collection Activities by Contact Type
Business Contacts
We collect and use business contact details for individuals associated with existing and potential Connor clients to manage and maintain our business relationships with those individuals. Connor uses a customer relationship management system via a 3rd party provider to store Personal Information about our business contacts.
The collection of Personal Information about contacts and the addition of that Personal Information to the 3rd party CRM is initiated by Connor staff and may include name, employer name, title, phone, email, and other business contact details. In addition, the 3rd party may collect data from Connor email and calendar systems concerning interactions between Connor staff and business contacts.
Through email applications, we may use technologies to determine engagement with emails, including whether they have been opened, or if contained links have been viewed. Information from multiple sources may be combined to assist with measuring interest in different Connor Services and email campaigns, to improve communications with target audiences, and tailor client interaction.
Unless we have been informed the contact would like to opt out or unsubscribe, we use client business contact details to provide information that we think will be of interest to the contact, including information about Connor Services. For example, we may send you industry updates and insights, information about other services, or regulatory updates.
Corporate Clients and related Individuals
Connor policy is to collect necessary Personal Information for agreed purposes and contractual obligations. Additionally, we ask our clients only to share Personal Information with us when it is needed for agreed purposes. When Connor processes Personal Information that has been provided by our clients, Connor asks our clients to provide the necessary information to the data subjects concerned regarding how Connor will process that Personal Information.
Where agreed with our clients, we may use information that we receive while providing services for lawful purposes, including to analyze an issue, industry or sector, provide information to our clients, improve our business, or develop new technologies.
Users of our websites
This section describes our privacy practices with respect to https://www.connor-consulting.com/When you access or otherwise use our Site, we may collect information about you and how you interact with our Site. We may collect information about you through:
(1) information you provide
(2) automatic tracking technologies
(3) third parties
When you visit Connor Sites, some information is automatically collected from devices used to visit our Sites, this information may include, IP address, browser type, browser language, pages viewed, time spent on a page, access times and information about your use of and actions on our Site. We also get information about in-bound domain names and pages viewed. This data tells us which pages our users visit and what information they volunteer, such as requests for contact or inquires in regard to different Connor services.
We may log information using Cookies. Cookies are small data files stored on your device by a website. We may use Cookies with various expiration dates to provide you with a more personal and interactive experience on our Site.
In all such cases persistent cookies are not used, and all cookies have an expiration date within 2 years or 13 months where applicable to comply to EUGDPR regulations.
See our Cookies Policy for more details.
Suppliers and Subcontractors
We may collect and process Personal Information about suppliers and subcontractors we do business with, including individuals associated with those suppliers/subcontractors. This information is used to manage relationships, contracts, to provide services to our clients and for receiving services from our suppliers. The Personal Information generally includes contact information for suppliers and subcontractors and may be stored in our 3rd party CRM.
How we Collect Personally Identifiable Information
Personally Identifiable Information (PII), (“Personal Information”) is information that identifies you, such as your name, phone number, email address, mailing address, or organizational affiliation.
We may collect Personal Information you provide to us over the phone, in email, through a face-to-face conversation, or through online and offline forms such as Connor newsletters, surveys or emails.
We may collect your name, email address, phone number, organization, reason for inquiry, name as well as other information you directly give us on our Site.
When you engage with Connor on social media, we may collect basic information on your profile, including your name and profile bio, the size of your following, your social sharing activity and your content preferences from social media platforms used by you.
We may collect information about you from other sources and we may add this to information we get from this Site.
We may also collect information from or about you from other public online and offline sources, such as LinkedIn, or information published in online or print media.
2. Use of Information
Personal Information
Connor will only collect and use Personal Information about you where we have lawful bases. Lawful bases includes when consent has been given, our legitimate interest in operating, managing and promoting our organization, maintaining our relationship with you and exercising our legal rights. Where we rely on your consent to process Personal Information, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your Personal Information, please contact privacy@connor-consulting.com.
Personal Information uses based on consent and/or legitimate interest:
To manage client relationships, including to communicate about industry or regulatory updates, new services offered, promotions, upcoming events, and other news about products and services offered by us and our selected partners.
To provide services and to support to clients.
To facilitate administrative operations including, sending confirmations, invoices, technical notices, updates, support, and administrative messages.
For business development purposes including, identification of new or potential client relationship opportunities, service improvements or to develop new services.
To evaluate the relationships between Connor and contacts and perform analysis on said relationships.
To perform analytics and produce metrics for Connor leadership. These metrics can include trends, sales intelligence, relationship maps, and progress towards business goals.
System and IT systems maintenance
To facilitate, host or run events.
To conduct surveys, questionnaires, or similar campaignsFor Security, quality, and risk management activities
Personal information may be processed for security monitoring. Including to detect, investigate and resolve security threats. For example, scans to identify phishing emails or other threats.
Information Combining, Aggregation and Analysis
We may combine and use data analysis to interpret your information and predict how likely you are to be interested in or responsive to particular compliance initiatives, advertising campaigns or related communication.
We may aggregate non-personally identifiable information collected from you and other users as well as device information or location information to produce general statistics that cannot be linked to you or any specific user and with which we attempt to provide you with a better experience on our Sites, to improve services, industry grouping, and to analyze and understand how our sites are used.
We may also share aggregated and/or anonymized data with others for their own uses.
Sharing
We may share your Personal Information as follows:
Sharing Information to protect our business.
We may share information to protect the rights and property of Connor, our employees, clients, and others. This includes enforcing agreements, policies, and terms of use. In the event of an emergency Connor may share information. This includes sharing information when necessary to protect the safety of our employees and clients, or any person. If necessary to protect the security or confidentiality of our records and in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with our rights.
Sharing with Service Providers.
Third party companies that we engage to process or collect information on our behalf based on our instructions are required to be in compliance with this Privacy Statement. For example, any Personal Identifiable Information (PII), submitted may be stored in a database of a third-party provider, where it is made available for Connor to download. This data may then be compiled in another trusted third-party database and/or customer relationship management tool.
Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation.Connor may receive requests, subpoenas, or court orders from authorities to obtain disclosure of Personal Information in order check that we are complying with applicable laws, regulations, to investigate alleged crimes, or for other legal purposes. Connor will only fulfill requests for personal information where we are permitted to do so in accordance with applicable law or regulation. Additionally, Connor will only share information if we believe doing so is reasonably necessary to comply with a law, regulation, or legal request; to protect the rights, safety, or property of the public, or Connor; or to detect, prevent, or address fraud, security or technical issues.
Sharing with Affiliates.
In the event of a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that Connor is engaged with, involving the transfer of information described in this Privacy Statement, we would share your information with a party involved in such a process (for example, the successor organization of Connor).
Sharing with Auditors, professional advisors, and insurers.
Connor engages auditors and other professional advisors, such as, law firms, as needed obtain advice in running our business, or to exercise, establish and defend our legal rights. Connor may share Personal information as necessary with these auditors and other advisors in connection with the services or products being performed. Connor also has insurance policies in place to protect our interests and in the event of a claim or other situation we may need to share Personal Information with the insurer.
Sharing for legitimate Business interests.
Connor only shares Personal Information with others when legally permitted to do so in compliance with all US law and GDPR regulations. When Connor shares data, Connor uses contracts, and security mechanisms where appropriate to protect the data in compliance with data protection, confidentiality, and security standards. For example, when we need to process Personal Information to in order to provide professional services for our clients, we may share Personal Information in reports that we make and deliver.
Retention
We retain collected Personal Information as long as considered necessary to fulfill the purposes for which it was collected. Personal Information may be kept for longer periods where extended retention is required by law, regulation, and/or professional standards. In addition, Personal Information may be kept longer to establish, exercise, or defend the legal rights of Connor. Additionally, in the case of business contacts Personal Information may be retained in our 3rd party client relationship management tool for as long as we maintain a relationship or need to maintain a record of that relationship.
3. Your Choices
You can control the type of information collected through our Sites, for example by not accepting cookies from our website, or by not providing Personal Information when prompted.
Information Choices and Changes
Our marketing emails tell you how to “unsubscribe.” If you unsubscribe, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.You may send requests concerning Personal Information to our contact information below. You can request to change contact choices, opt-out of our sharing with others, and update your Personal Information.
Communication Choices
If you wish to update your Personal Information with us or change your communications preferences or if you no longer wish to receive communications from us, please click on the “unsubscribe” link in the email to unsubscribe or tell us so by email, phone, or written letter. Please include your exact name and contact details so that we can correctly remove you from our mailing list. Our mailing address is Connor Consulting Corp. 300 Brannan St. Suite 207, San Francisco, California 94107. We can be reached via email at privacy@connor-consulting.com
Cookie Choices
As referenced in Section 1. Connor uses cookies on its website. You can reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.For more information on cookies including how to opt-out please see our Cookie Policy.
4. Security
Connor has implemented appropriate and reasonable administrative, physical, and technical safeguards to protect Personal Information and data from loss, misuse, alteration or destruction.
Only employees who need the information are granted access to personal information, following the principles of least privilege. Please note that in the unlikely event that we might need to contact you about a matter involving your Personal Information, we may email you about the matter.
5. Linked Websites
Our Sites contains links to other websites. Connor is not responsible for the privacy practices or the content of such websites.
As part of this Site or our Service(s), we may provide links to other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Statement applies solely to information collected by us through this Site and the Services performed by Connor. Therefore, this Privacy Statement does not apply to your use of a third-party website accessed by selecting a link on our Site or via our Services. To the extent that you access or use the Services through or on another website or application, then the Privacy Statement of that other website or application will apply to your access or use of that site or application.
Connor encourages our users to read the respective privacy statements and/or policies of other websites before proceeding to use them.Connor, with its partnership and commitment to security and privacy with Microsoft, also provides a link to their Privacy Statement.
6. Children’s Privacy
We recognize the importance of protecting the privacy of children on the web and will never collect or maintain information at our Site from those we know are under 13 years old. No part of our website is directed at children under the age of 13, and we do not knowingly collect Personal Information from children under age 13. If we discover that a person under the age of 13 has provided us with any Personal Information, we will delete that information from our systems. Connor does not reply to information requests from children under the age of 13, if so identified. A parent or guardian must initiate any requests for information from children under the age of 13 on their behalf.
7. Notices to Residents of Certain Jurisdiction
California Residents
It is our policy not to disclose any Personal Information we collect to third parties for direct marketing purposes under any circumstances. However, California Civil Code Section 1798.83 requires that all California residents be afforded the option to exercise their choice of whether Personal Information may be shared with third parties for direct marketing purposes or not, as well as to receive information specified in the statute if Personal Information is disclosed to third parties for direct marketing purposes.
If you are a California resident, effective January 1, 2020 you have the following additional rights:
Right to Know.
You have the right to request information about the categories and specific pieces of Personal Information we have collected about you in the preceding 12 months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information.You have the right to request information about our sale or disclosure for business purposes of your Personal Information to third parties.
Right to Request Deletion.
You have the right to request the deletion of your Personal Information.
Right to Non-discrimination.
You have the right to not be discriminated against for exercising any of these rights.
Only you, or a person you designate to act on your behalf, may make a verifiable consumer request related to your Personal Information. We may request that your authorized agent have written authorization to make the request on your behalf and may need to verify the authorized agent’s identity.
In some instances, you may be requested to verify your identity prior to access or deletion of your Personal Information such as a government issued ID. Once identity has been verified, the request will proceed.
Accordingly, you are a California resident and if you wish to inform us whether you permit or refuse the sharing of your Personal Information with third parties for direct marketing purposes, or if you wish to request certain information if your Personal Information were to be disclosed to third parties for direct marketing purposes, please contact us as described in the section 3., Your Choices.
EU and UK Residents
In accordance with applicable law, you are entitled to know what Personal Information we hold about you and you may ask us to make any necessary corrections to ensure that it is accurate and kept up to date. Under applicable law, you also have the right to request deletion of your Personal Information or to object to the processing of your Personal Information. If you wish to exercise your rights, please contact us as detailed in section 3 (Your Choices). You may also have a right to complain to your data protection authority. Although Connor is a global company, our headquarter is based in the United States. Please be aware that if you submit information to us, it will be stored on servers in the United States.
Mexico Residents
You can contact us as described in section 3. (Your Choices) to enforce your privacy rights at any time, including to access your data, ask for your data to be updated, amended or deleted as well as to oppose the way we use your Personal Data. You may also contact us to request to revoke your previously granted consent to the extent permitted by law. Through the same contact data, we may inform you about:
The information that you will be asked to provide to identify yourself as well as the documents you may need to enclose with your request.
Timeframes to receive a response regarding your request.
Forms available for submitting your request, including template forms that you may use to apply, if available, and the channel through which our answer will be delivered to you;
How we will deliver your information to you (which usually would be copies of documents, data messages).
Australia Residents
If you have any questions, comments, or complaints about our collection, use, or disclosure of Personal Information, or if you believe that we have not complied with this Statement or the Privacy Act 1988 (Cth), please contact us as detailed in section 3. (Your Choices). When contacting us, please provide as much detail as possible in relation to your question, comment, or complaint. We will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need. If you are not satisfied with the outcome of our assessment of your complaint, you may wish to contact the Office of the Australian Information Commissioner. For more information, please refer to www.oaic.gov.au.
8. Cross Border Transfers
Connor is a global firm, with personnel operating across the globe. In addition to our staff, we use international third parties to help run our business. Because of the global nature of our business, Personal Information may be stored processed or transferred outside the countries where our clients are located unless specified otherwise due to contractual obligations. This includes transfers to countries that are outside the European Economic Area (“EEA”) and to countries that may not have laws that provide the same degree of protection for Personal Information as the country of origin for the data subject. In accordance with applicable law and regulation, Connor takes appropriate measures to facilitate adequate protection for any information that has been transferred.
When we transfer Personal Information outside of the EEA to a country or framework not determined by the European Commission as providing an adequate level of protection for Personal Information, the transfers will be under an agreement which covers European Union requirements for such transfers, such as standard contractual clauses.
Connor also adheres to the EU - U.S. Privacy Shield Framework and the Swiss - U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce.
Your Personal Information may be stored and processed in any country where we have facilities or service providers, and by using our Sites and providing Personal Information to us, or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country. Where required, we have implemented appropriate cross-border transfer solutions to provide adequate protection for transfers of certain Personal Information, including, but not limited to, the European Commission’s Standard Contractual Clauses.
9. Data controller and contact information
Connor is often considered to be the data controller when processing Personal Data while providing our professional services. However, in some cases during audits or other professional services Connor would be considered a data processor. If there are any questions about the role that Connor is fulfilling while processing data, please use the contact information below.
Data Protection Officer
Connor Consulting Corporation3
00 Brannan St #511 San Francisco, CA 94107
Email: privacy@connor-consulting.com
10. Changes to this Privacy Statement – “Online Privacy Statement
”We reserve the right to modify or supplement this statement at any time. If a material change to this policy is made, we will post a notice on the home page, and any changes to the statement will be posted on this page.
11. Data Subjects and the Rights of Individuals.
There are certain rights individuals have over their Personal Data. These rights include the following:
Right to access,
Right of rectification,
Right of erasure or deletion,
Right to restrict processing,
Right to object to processing
Right of data portability,
Right to withdraw consent at any time (where processing is based on consent).
Please see below for more information on these rights.
Right to access
Individuals have the right to obtain confirmation regarding the retention of Personal Data we may hold about them. To request a copy of the Personal Data we control, and information regarding how and for what reason we process their Personal Data. This right may be exercised by emailing us at privacy@connor-consulting.com
Right to Rectification / Amendment
Individuals have the right to request that their Personal Data to be amended or rectified where/if it is inaccurate, and to complete any incomplete data.
To update your Personal Data, please email us at privacy@connor-consulting.com
When practically feasible, once informed that any Personal Data processed by us is inaccurate, we will make updates as appropriate.
Right to erasure
In the following circumstances to you have the right to deletion for your Personal Data:
When the Personal Data is no longer necessary in relation to the purposes for which it was collected and processed
When our legal basis for processing is consent, and consent is withdrawn, and no other lawful basis applies.
When our legal basis for processing is that the processing is necessary for legitimate interests pursued by us or a third party, you object to our processing and we do not have overriding legitimate grounds.
When you unsubscribe or object to processing for direct marketing purposes.
If Personal Data has been unlawfully processed
In the event your Personal Data must be deleted to comply with a legal obligation.
To request deletion of your Personal Data, please email privacy@connor-consulting.com
Right to restrict processing
In the following cases You have the right to restrict processing of your Personal Data:
In the event the accuracy is contested, for a period enabling us to verify the accuracy of your Personal Data.
In the event your Personal Data has been unlawfully processed.
In the event your Personal Data is longer necessary in relation to the purposes for which is was collected and processed but the Personal Data are required by you to establish, exercise or defend legal claims
In the event an individual objects to our processing for a period enabling us to verify whether the legitimate grounds relied on by us override your interests.
To restrict our processing of your Personal Data, please email us at privacy@connor-consulting.com
Right to object to processing
Individuals have the right to object to our processing of their Personal Data when:
Process is based on our legal basis for our legitimate interests or those of a third party.
Processing is for direct marketing purposes.
To object to processing of your Personal Data, please email us at privacy@connor-consulting.com
Right to data portability
When the legal basis for processing an individual’s Personal Data is consent or performance of a contract, they have a right to receive their Personal Data provided by the Individual to Connor and/or to have this sent to another organization when feasible.To exercise this right to data portability, please email privacy@connor-consulting.com
Right to withdraw consent
Where we process Personal Data using only your consent, you have a right to withdraw this consent at any time. Note this is not our normal legal basis for processing data and is not always applicable.
If you wish to exercise the right to withdraw your consent, please email us at privacy@connor-consulting.com
To unsubscribe from direct marketing, please click on the “unsubscribe” link in the relevant email.
12. QuestionsIf you have any questions about our privacy statement or the practices of this site, please contact us at privacy@connor-consulting.com.
Connor Consulting Corp.
300 Brannan St. Suite 511
San Francisco, California 94107
Attn: Privacy Officer
Effective Date: This Privacy Statement was last revised March 1, 2024.
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This site “connor-consulting.com” uses cookies to improve performance, better enhance your browsing experience and to protect this site against potential spam. In addition to this site this policy is applicable to any Connor Consulting Corp (“Connor”) site or service which supplies links or references to this policy.If you have any questions in regarding our use of cookies on our site, please contact us at privacy@connor-consulting.com.
What is a Cookie?
Cookies are small data files stored on your device by a site or website. These cookies enable certain features and or functions on our sites and serve to provide a more personal and interactive experience.
Cookie Use?
Necessary Cookies
These cookies are necessary to operate our site and required for it to function. These cookies can only be disabled through your browser settings or preferences.Performance and Analytics Cookies
These cookies are used to monitor, measure and report site activity on our site. These cookies track page visits, geographic information, views, and how visitors/users interact with and move around the site. The information collected is not personally identifiable.
Marketing Cookies
Marketing cookies help us provide personalized and relevant services or advertising and monitor digital marketing activity effectiveness. Marketing cookies may also interact with third party providers. For additional information regarding our suppliers and how these cookies operate please email us at privacy@connor-consulting.com.
Cookie Duration
Session cookies are cookies that remain in your browser while visiting the site until the browser or site is closed.
Persistent cookies are cookies that remain on your device/browser until they have either expired or deleted, whichever occurs first.
Connor may use cookies with various expiration dates to facilitate and provide the features and services listed in the “Cookie Use” section above. In all such cases cookies will not have an expiration date greater than 13 months.
Cookie Choices
You have the right to choose to accept or reject the use of cookies. However, if you choose to refuse the use of cookies, you may not be able to use the full functionality of our site.If you do not want to accept receive or use cookies, you may change your cookie settings for Connor’s site in your browser settings/preferences.
Privacy Statement
Please review our Privacy Statement for additional details about how we collect, use, and disclose information in connection with our Sites.
Cookies That Have Been Set in the Past
Information obtained from previously accepted cookies prior to any preference change indicating a rejection of the use of cookies may still be used. However, we will stop using the rejected cookie to collect any further information, and that cookie will be disabled.
Changes to Cookie Policy
We may update this Cookie Policy to reflect changes in our practices and services. In the event a change is made to this Cookie Policy, we will revise the “last revised” date at the bottom of this page. If any material changes are made in the way we collect, use, and/or share information held in cookies, we will notify you by prominently posting notice of the changes on the site and the applicable policies such as this Cookie Policy and/or our Privacy Statement.
Questions
If you have any questions about our Cookie Policy or the practices of this site, please contact us at
privacy@connor-consulting.com.
Connor Consulting Corp.
300 Brannan St. Suite 511
San Francisco, California 94107
Attn: Privacy Officer
Effective Date: This Privacy Statement was last revised March 1, 2024
Introduction and Purpose
Connor Consulting Corp’s (“Connor”) reputation derives from our commitment to our core values: collaboration, integrity, positivity, trust, diversity, accountability and accessibility for our customers and partners. Connor’s Code of Ethics (the “Code”) provides guidance to Connor employees, consultants, independent experts, interns, and volunteers in living Connor’s core values, and outlines minimum standards for ethical conduct which all staff must adhere to.
Connor relies on the personal integrity, good judgement and common sense of individuals acting on behalf of the organization to deal with issues not expressly addressed by the Code. Failure of a staff member to adhere to the Code may result in disciplinary action up to and, including discharge from employment and filing of criminal charges.
Connor employees, consultants, independent experts, interns and volunteers shall:
Integrity
Act in good faith, responsibly, with due care, competence and diligence and maintain the highest professional standards at all times.
Comply with Connor policies as well as all applicable laws, rules and regulations, domestic and international, in every country where Connor works.
Reflect actual expenses or work performed in expense reports, timesheets, and other records.
Never engage in any of the following acts: falsification of business documents, theft, embezzlement, diversion of funds, bribery, or fraud.
Transparency
Perform duties, exercise authority and use Connor resources and assets in the interest of the organization and never for personal benefit.
Avoid conflicts of interest and not allow independent judgment to be compromised.
Not accept gifts or favors in excess of $150 from vendors, consultants or grantees.
Accountability
Disclose to a supervisor and the General Counsel’s Office, at the earliest opportunity, any information they have or become aware of, that may result in a real or perceived conflict of interest or impropriety.
Exercise responsible stewardship over Connor’s assets and resources; spend funds wisely, in the best interests of Connor and in furtherance of its mission. Adhere to and respect the wishes of its donors.
Manage programs, activities, staff and operations in a professionally sound manner, with knowledge and wisdom, and with a goal of increasing overall organizational performance.
Confidentiality
Not disclose confidential information obtained during the course of their work at Connor.
Protect confidential relationships between Connor and its grantees, donors, and vendors.
Mutual Respect and Collaboration
Assist its partners in building the necessary capacity to carry out conservation programs efficiently and effectively and to manage funds in a fiscally and operationally prudent manner.
Create constructive relationships with grant-seekers and other partners based on mutual respect and shared goals by communicating clearly and timely and respecting our partners’ expertise in their field of knowledge.
Engage with indigenous peoples and local communities in which Connor works in a positive and constructive manner that respects the culture, laws, and practices of those communities, with due regard for the right of free, prior and informed consent.
Any violations of the Code of Ethics should be reported to Connor Consulting Corp via its Ethics Hotline at www.ci.ethicspoint.com.
Connor Consulting Corp takes a zero-tolerance approach to fraud, bribery, and corruption and will uphold all applicable laws relevant to countering and investigating such activities across its global operations.
Connor is committed to:
Developing an anti-fraud culture across the organization.
Seeking to minimize the opportunities for fraud, bribery and corruptionhaving effective systems, procedures and controls in place to enable the prevention and detection of fraud, corruption and bribery.
Ensuring that its staff are aware of the risks of fraud, bribery and corruption and understand their obligations to report any actual or suspected incidents of fraud, bribery or corruption.
Taking all reports of fraud, bribery and corruption seriously, and investigating them proportionately and appropriately
Meeting its obligations to report any incidents of fraud, bribery and corruption to appropriate external authorities.
The aim of Connor’s Anti-Fraud Policy is to: set out Connor’s responsibilities in observing and upholding its policy on fraud;
Provide information and guidance to Foundation employees and partners, grant recipients and their associates on how to recognize and deal with fraud issues; and...
Establish standards of conduct for Foundation employees and partners, grant recipients and their associates so as to ensure that the relevant legislation is not violated.
Connor’s Anti-fraud policy applies to all staff members, Connor contractors, experts, consultants and grantees. It is an integral part of Connor’s internal control policy framework and should be read and applied in conjunction with Connor’s Code of Ethics. It forms part of a series of related policies and procedures developed to provide sound internal financial controls and to counter any fraudulent activity. These include: codes of conduct for staff and trustees; anti-corruption and bribery policy; sanctions policy; safeguarding policy; privacy policies; sound internal control systems; effective internal audit; effective recruitment and selection procedures; disciplinary procedure; public interest disclosure (whistleblowing) procedures; and training.
Reporting Fraud
Connor has established an ‘Ethics Hotline’ to ensure that persons can report fraud. Anyone with information regarding fraud or other corrupt practices against Connor or involving Connor staff, non-staff personnel, vendors, implementing partners and responsible parties, is strongly encouraged to report this information through the Hotline and will not be retaliated against for submitting such claim in good faith. The Investigations Hotline is managed by an independent service provider on behalf of Connor to protect confidentiality, and can be directly accessed worldwide in different ways:
Alternatively, complaints can be sent directly to
Connor by emailing privacy@connor-consulting.com.
or by mail to:Connor Consulting Corp.
300 Brannan St. Suite 207
San Francisco, California 94107
Attn: Privacy Officer
All allegations of fraud and corruption are taken seriously. Upon receipt of an allegation, Connor will assess the case and to determine if there is sufficient ground to warrant an investigation. Investigations will follow the guidelines outlined below.
Investigating Fraud
Depending on the nature, magnitude and the complexity of the fraud, investigations will be carried out by either Connor’s General Counsel or by an external firm with specific expertise to deal with the particular allegation.
Investigations will be conducted without regard to any person’s relationship to the organization, position or length of service. The investigating party will have full access to any files, information or witnesses to conduct the investigation and will keep records of all actions in the investigation, to ensure success in any future criminal, civil or disciplinary action.
The investigating party will issue a report detailing the finding and conclusion of the investigation, including recommendations for future action. The report will be disseminated to and reviewed by Connor’s Senior Leadership and Audit Committee in a timely manner. Unless earlier notice is required by the donor, Connor will inform other parties, including affected employees, external partners and donors of the conclusion of the report as needed.
In cases of substantiated fraud, Connor will pursue disciplinary or criminal sanctions where appropriate and possible and will attempt to recover losses by any lawful means.
All staff member shall at all times exercise good faith in all matters relating to their duties and responsibilities to Connor, act in the best interest of Connor when discharging their duties and comply with Connor’s Code of Ethics.
No staff member shall use their position or confidential information obtained in the course of employment to their personal advantage or for any other purpose not specifically approved by Connor or be influenced in the discharge of their duties by any personal, financial, or other interest, involvement or relationship they may have.
Each employee is responsible for recognizing a potential conflict-of-interest and for disclosing it pursuant to the procedures described below.
A conflict of interest exists or may exist whenever an employee or his/her family member has any involvement, interest or relationship, directly or indirectly, in a proposed transaction with Connor from which the employee or his/her family member receives, or may be perceived as receiving, a financial or other personal benefit. Employees are required to report each such transaction with a family member, regardless of whether preceding transactions with the same family member have been reviewed and approved.
A “family member” is defined as a spouse or domestic partner, children and their spouses, parents, siblings and their spouses, grandparents, grandchildren and their spouses, aunt, uncle, first cousin, niece, nephew, corresponding in-law, and respective “step” relations.
Examples of Conflicts of Interest Requiring Disclosure
Some examples of conflict requiring disclosures are included below. This list is not intended to be exhaustive.
A Family Member of a Connor employee applies for an employment position at Connor, or with an organization funded by Connor.
A Family Member of a Connor employee is considered for a consultancy with Connor, or with an organization funded by Connor.
A Connor employee or Family Member of a Connor employee sits on the board of directors/trustees of an organization funded by Connor.
A Connor employee or Family Member of a Connor employee has an ownership interest in, is employed by, or sits on the board of directors of a company that provides goods or services to Connor.
A Connor employee, his/her Family Member, or an entity in which the employee or his/her Family Member has an ownership interest, is offered any incentive, payment, loan, or gift of any kind with a monetary value greater than US$150, from or on behalf of any person or organization engaged in any transaction with Connor.
A Connor employee engages in consulting activities or enters into an employment relationship with an entity whose activities are in conflict with the activities or mission of Connor. (Note: Any such activity also requires prior approval of the supervisor and division head, see Outside Employment below)
Disclosing Conflicts of Interest
All Connor employees are required to complete and sign annual conflicts of interest disclosure forms. These forms are provided to employees at the start of each fiscal year by the General Counsel’s Office (GCO).In addition to these annual disclosures, if a proposed transaction arises in which an employee has, or believes s/he may have, a conflict of interest, the employee is required to make an immediate disclosure to the GCO and his/her immediate supervisor, using the conflicts of interest disclosure form available on the Intranet. This disclosure must be done prior to any consideration or execution of the proposed transaction by Connor.
Process for Resolving Conflicts of Interest
The employee shall not participate in the deliberations on the matter but shall disclose any material facts related to the proposed transaction. Upon a determination by the GCO that a conflict of interest exists, the GCO, working with the supervisor or division head, may request that that appropriate actions be taken to resolve the matter. The GCO shall maintain a record of the existence and resolution of the conflict of interest. In some cases these conflicts may be reported in public filings. If the matter cannot be resolved in a satisfactory manner, but the employee, his/her supervisor and/or the respective division head are of the opinion that the transaction is nonetheless beneficial to the overall interests of Connor, the respective division head and the Connor shall bring the matter to the attention of the Chief Executive Officer who shall make the final determination whether to pursue the transaction; provided, however, that if the employee is also an officer or in a position to exert substantial influence over the affairs of the organization, then the matter is referred to the Compensation Sub-Committee of Connor’s Board of Directors in accordance with its procedures for addressing conflicts of interest.
Employment of Family Members
Employment of Family Members may constitute a conflict of interest. Employees must disclose all such relationships to their supervisor and to the GCO using the conflicts of interest disclosure form available on the Intranet, or the annual disclosure form as appropriate. This disclosure must be done prior to employing any Family Members.Employees who marry while employed or become part of the same household will be treated in accordance with the policy on personal relationships.
Outside Employment
Employees may not engage in any outside consulting or employment that conflicts with the interests of Connor. Employees are required to fulfill the responsibilities of their position, and any external employment activity that results in neglect of the employee’s job responsibilities is inappropriate. Employees should obtain written approval from their supervisor and the division head to engage in any outside consulting activity or employment.
Connor Consulting Corp’s reputation is a reflection of our commitment to the core values of collaboration, integrity, positivity, trust, diversity, accountability and accessibility for our customers and partners. We are committed to lawful and ethical behavior in all of our activities and require our staff and partners to conduct themselves in a manner that complies with all applicable laws and regulations. If at any time a concern regarding the propriety or legality of any action contemplated to be taken or that has been taken by Connor Consulting Corp., an employee, grantee, or partner arises, please report the issue immediately.
Reports should be submitted to Connor’s Ethics Hotline. This resource provides employees, grantees, and other partners and beneficiaries with a globally accessible, multilingual reporting tool the gives the ability to report incidents anonymously. It is available 24 hours a day, seven days a week, by logging on to at www.connor.ethicspoint.com or by dialing a toll-free number from anywhere in the world where Connor works that can be found on the website.
No employee or any other person will be discharged, threatened, or discriminated against in any manner for reporting in good faith what they perceive to be wrongdoing, violations of law, or unethical conduct.
Retaliation against any person who submitted a claim in good faith is subject to disciplinary action up to and including termination for cause and grantees or partners may be disqualified from submitting future funding proposals to Connor Consulting Corp.
The purpose of this Notice is to explain how Connor Consulting Corp collects, uses and handles (processes) personal information about our job applicants in connection with our online and offline recruitment activities and to explain the rights that they have under data protection law. In this Notice, we refer to this type of information as “Recruitment Data”.This Notice applies to applications submitted via our website and third parties, such as recruitment agencies and job boards. It also applies to applications submitted via other means, such as by post, recruitment events and email.Connor Consulting Corp means Connor and any of its subsidiaries and affiliates, as existing from time to time. Conservation International is also referred to in this Notice as “we”, “us” or “our”.
1. What Recruitment Data do We Collect?We will generally only collect Recruitment Data in the recruitment process that is necessary to assess you for the position for which you have applied. This may include the following categories of data:Application information: This information will generally tell us who you are and help build a picture of your capabilities and suitability for certain positions. This type of information may include your name, contact information, current company, information contained in your CV/resume (e.g. professional qualifications, previous employment history, place of residence), your eligibility to work in the jurisdiction where the position is located, information contained in your publicly available social media accounts or personal websites (e.g. LinkedIn or Twitter), information about the type of work and projects you have been involved with and any other information you may wish to provide to us as part of your application.Recruitment process information: This is information collected as a result of the recruitment process, such as your performance at assessment centres or interview and information provided by your references.Future opportunities information: This is information collected in order to keep in touch with you about future job opportunities at Connor such as your name, email, LinkedIn profile, location, field of expertise and the kind of role you are interested in.Website information: If you submit your application via our website, this is information related to your use of our website, for example your IP address. This information may be collected using cookies and similar technology. For more information about how we use cookies and similar technologies please see our Website Privacy Notice.We generally receive Recruitment Data either (a) directly from you (for instance when you provide information as part of your application or during the recruitment process) or (b) from third parties (for instance from recruitment agencies). We will indicate where the information we have requested is mandatory or optional. We will also explain the consequences should you decide not to provide information which we have indicated is mandatory. In some circumstances this may mean we are unable to process your application.Note: Background check information (such as criminal background, credit check depending on the position you apply for and the region where the position is located) will only be sought where permitted by applicable law and is subject to execution of a separate, specific consent. Connor collects disability related information only to the extent volunteered by you and will process such information only to the extent allowed and in accordance with applicable law.
2. What Will We Do with Your Recruitment Data?The main purposes for which we use your Recruitment Data include:Supporting and Processing your Application, for example, so we can assess your ability to meet the job specification, in order to shortlist applicants and to verify references and professional qualifications provided by applicants.Improving our Application Process, for example, to ensure that the careers section of our website is user-friendly and contains appropriate and helpful information.Safety Management, for example, to ensure the safety of our premises, assets, information, employees and other personnel.Legal and Regulatory Compliance, for example, to ensure compliance with health & safety requirements and other legal or fiscal obligations, or in connection with litigation or an internal investigation or audit and to ensure compliance with our policies regarding anti-money laundering, bribery and corruption, as well as equal opportunities monitoring.Ensuring compliance with our Code of Ethics/Conduct, for example to ensure that we are living up to our valuesWe may verify the Recruitment Data you provide during the recruitment process and/or collect personal data about you from third party sources to assist with our “Pre-Employment Checks”. If this occurs:You will be told in advance which aspects of your Recruitment Data will be verified including an explanation of how the Pre-Employment Checks will be carried out; andInformation about criminal convictions or credit-related information (to the extent necessary to conduct background checks for certain positions with increased fiduciary responsibilities) will only be collected through official authorized sources, subject to your informed consent and in accordance with applicable law.We will only process your Recruitment Data where we have a legal basis for doing so. Generally, we will be processing it to help us to decide whether to enter into a contract of employment with you. At other times, we will be processing your Recruitment Data because you have consented to us doing so, in which case you can withdraw such consent at any point.We may also process your Recruitment Data to comply with our legal obligations or because it is in our legitimate business interests to do so (for example, where it is necessary to understand our applicants in sufficient detail so we can operate an effective recruitment process).
3. Whom is Your Recruitment Data Disclosed to?(a) Within ConnorWe restrict access to Recruitment Data to people within our group of companies who have a “need to know” such information. For example, certain individuals within Connor will have access to your Recruitment Data in order to process your application and manage the recruitment process (this may include individuals in our Human Resources team and individuals to whom you would report if your application is successful).(b) Outside ConnorWe share Recruitment Data with authorized third-party service providers to conduct and manage the recruitment process. For example, we may share your Recruitment Data with such service providers in order to conduct screening and verification of your application and the information you have provided to us. This may include verifying academic and professional qualifications. Generally, we will only disclose your Recruitment Data to our suppliers and other third parties in the following circumstances:when required to do so by law;in response to a legitimate request for assistance by the police or other law enforcement agency; and/orto seek legal advice from our external lawyers or in connection with litigation with a third party.
4. How Long Will We Retain Your Recruitment Data?We keep your Recruitment Data in accordance with our internal retention policies and procedures. Typically, if you are unsuccessful in your application with us (or if you reject the position), we will keep your Recruitment Data for three (3) years following submission by you.
5. Where Do We Store Your Recruitment Data?Applicants in the European Economic Area (the “EEA”) and the UK should be aware that their Recruitment Data may be transferred to, and stored at, a destination outside the EEA and the UK in countries, which have less strict, or no data protection laws, when compared to those in Europe. It may also be processed by staff or our vendors in other non-EEA jurisdictions which also have less strict or no, data protection laws.Whenever we transfer your Recruitment Data outside of the EEA or the UK, we will take legally required steps to ensure that adequate safeguards are in place to protect your Recruitment Data and to make sure it is treated securely and in accordance with this Notice. If you are located in the EEA or the UK, you may contact us for a copy of the safeguards which we have put in place to protect your Recruitment Data and privacy rights in these circumstances.
6. Exercising Your RightsYou may have the right to request access to, rectification or erasure of, the Recruitment Data we hold about you. You may also have the right to object to or restrict certain types of processing of your Recruitment Data and request to receive a machine-readable copy of the Recruitment Data you have provided to us.If you notice an error in your application that you would like to correct, please contact us using the contact information below.Any request to exercise one of these rights will be assessed by us on a case-by-case basis. There may be circumstances in which we are not legally required to comply with your request, for example, because of relevant legal exemptions provided for in applicable data protection legislation.
7. Contact UsPlease contact us at the address below, if you would like to find out more about any matters relating to this Notice or if you have concerns about the way in which we have processed your Recruitment Data:Connor Consulting Corp.300 Brannan St. Suite 207San Francisco, California 94107Attn: Privacy OfficerWe can also be reached via email at privacy@connor-consulting.com or by telephone at (703) 341-2400.If you are still dissatisfied, you have the right to complain to your Data Protection Authority.
8. Updates to this NoticeWe may change this Notice from time to time in order to reflect changes in the law, regulatory guidance or our data privacy practices in compliance with the law. When this happens and where required by law, we will provide you with a new or an updated notice detailing how the use of your Recruitment Data is changing and, if necessary, obtain your consent for further processing.
This Notice was last updated on April 7, 2021
Connor does not tolerate bribery, kickbacks, or corrupt acts of any kind or in any circumstances from Connor staff, or its clients, agents, consultants, licensees, vendors, or representatives of any kind.
Corruption is the misuse of power for private profit or gain. Bribery is broadly defined as offering to make or making a payment, or offering to provide or providing anything of value, to influence a decision or create an improper advantage. This prohibition includes making or offering to make payments through intermediaries or to third parties; and it does not require that payments actually be made.
Staff must abide by all applicable anti-bribery and anti-corruption laws. All Connor staff in all countries are subject to the U.S. Foreign Corrupt Practices Act (“FCPA”). The FCPA prohibits improper payments to government officials and officials of public international organizations. Connor staff living or working in countries other than the US may also be subject to national anti-corruption laws. All staff are required to raise potential issues before they lead to problems and to seek additional guidance when necessary.
Connor considers compliance with anti-corruption laws, and with Connor’s internal policies relating to anti-corruption, to be a serious matter, and will thoroughly investigate any allegations of bribery. Connor employees, and others working on Connor’s behalf or for its benefit, who do not comply with such laws and policies may be subject to disciplinary action up to and including termination of their employment or other relationship. In addition, individuals violating applicable anti-corruption laws may be subject to a range of penalties, which could include fines and imprisonment.
