LATEST BLOG POST: How Petroleum Geoscientists Can Contribute to Geothermal Energy
Information for individuals who are or were employees, interns or individual contractors as well as dependents of ThinkOnward employees.
ThinkOnward is part of the Shell group of companies. As such, this Privacy Notice aligns with the standards and practices adopted across Shell entities and reflects our commitment to safeguarding personal information in accordance with applicable laws and Shell’s global privacy principles. This notice sets out what personal information we collect, for what purposes and your rights in this respect.
Every individual within ThinkOnward is responsible for protecting personal information about each other as well as that of our customers, business partners and suppliers.
This Privacy Notice provides information about personal information processed by ThinkOnward in relation to individuals who are or were employees, interns or individual contractors as well as dependents of ThinkOnward employees (‘ThinkOnward Staff’). It outlines ThinkOnward’s relationship with Insperity as a co-employer and clarifies which policies apply to each group.
For visitors of ThinkOnward websites or users of ThinkOnward applications, please refer to the Privacy Notice - ThinkOnward App users and visitors to ThinkOnward websites at https://www.thinkonward.com/business-privacy-notice.
For individuals who apply to work for ThinkOnward or who attend a recruitment event or undertake an assessment please refer to the Privacy Notice – ThinkOnward Recruitment at https://www.thinkonward.com/recruitment-privacy-notice.
As well as this Privacy Notice, bespoke privacy notices and supplementary privacy statements may contain further information about how we process your personal information in relation to specific HR processes In those instances, such privacy notices will be communicated to you separately, for example the HIPAA privacy notice.
This Privacy Notice explains what personal information are processed about you, why we are processing your personal information and for which purposes, how long we hold your personal information for, how to access and update your personal information, as well as the options you have regarding your personal information and where to go for further information.
Co-employment with Insperity
ThinkOnward operates under a co-employment model with Insperity:
ThinkOnward manages work assignments, performance, and operational oversight and Insperity handles payroll and benefits. This means that both parties process personal data in the context of the employee / staff relationship. Both parties are responsible for their own processing activities and describe the relevant processing activities in their own Privacy Notice. For all information regarding the processing of personal data for which ThinkOnward is responsible, please see this Privacy Notice. If you have any questions about the processing of your personal data in the context of your employment relationship, you may contact ThinkOnward or Insperity.
As a result:
ThinkOnward employees are also subject to Insperity's employment policies, including its privacy standards.
Secondees are not co-employed by Insperity and are exempt from Insperity's employment policies. Their data is governed solely by ThinkOnward's internal privacy framework.
ThinkOnward does not knowingly sell or share your personal information for cross-context behavioral advertising and/or for targeted advertising purposes.
Special Notice: Processing children’s personal information (if you are under 13 years old): Except in those cases where ThinkOnward organizes educational events
specifically designed for children, we do not intentionally collect personal information of individuals under 13 years old.
What categories of personal information do we process about you?
Collection of information. We process personal information necessary to manage the employment relationship, to engage contractors and interns and to provide benefits to certain dependents of ThinkOnward employees.
This includes personal home contact information, date of birth, marital status, payroll and bank account information, wage and benefit information including beneficiary information, emergency contacts, work performance information, information required to ensure you have the right to work in the country/ies you are engaged in, as well as any other information necessary for managing the employment relationship, for engaging contractors and for providing benefits to certain dependents of ThinkOnward employees (such as those dependents who accompany a ThinkOnward employee while on an expatriate assignment).
Sensitive personal information. We also process some special categories of personal information (’sensitive personal information) such as data relating to an individual’s health, their racial or ethnic origin, religious or philosophical beliefs, sexual orientation, political opinions and trade union membership.
We will only process such personal information where:
it is necessary for the purposes of complying with employment and social security laws including those specifically for the purposes of ensuring equal employment opportunities as required by US law, covering applicant and employee information such as gender, race/ethnicity, nationality, disability and veterans status;
for the establishment, exercise or defense of claims;
where necessary for the purposes of providing occupational medical advice and support, to protect the vital interests of an individual (such as in an emergency), where necessary for reasons of public health;
or where the individual has provided their explicit consent (only if required by local law).
Why do we process your personal information?
We process your personal information:
in order to satisfy our obligations to comply with local laws and regulations;
for legitimate business interests (for example performance management in order to ensure we have qualified and competent personnel or for health, safety and security purposes to ensure that only authorized personnel can access certain sites or assets, litigation and defense of claims); or
where we have your explicit consent, including opt-in consent to process sensitive personal information where local law applies.
Please note that as a general principle, ThinkOnward does not seek or rely on the consent of ThinkOnward Staff for processing personal information. However, there are limited circumstances when consent is required.
Personal information requested from ThinkOnward Staff are the minimum required in order to fulfil legal and/or contractual requirements and to provide opportunities to take part in programs or to provide a benefit. Failure to provide us with the information requested may negatively affect your ability to remain in employment, internship or engagement as a contractor or from participating in a program or receiving a benefit.
In those cases where processing is based on consent, and subject to applicable local law which provides otherwise, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent. Withdrawal of consent may however impact your ability to remain employed or otherwise engaged or from participating in a program or receiving a benefit.
For what purposes do we process your personal information?
We process personal information covered by this Privacy Notice for the following purposes:
Human Resources, personnel management, business process execution, internal management, management reporting, organizational analysis and development - including budgetary, financial and organizational planning, administration, compensation, performance management;
Health, safety and security - including protection of ThinkOnward Staff’s life or health, occupational health and safety, protection of ThinkOnward assets and authentication of ThinkOnward Staff status and access rights; or
Legal and/or regulatory compliance - including compliance with legal or regulatory requirements.
We may also process your personal information for a secondary purpose where it is closely related, such as:
storing, deleting or anonymizing your personal information; fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defense of claims; or statistical, historical or scientific research.
Monitoring
All activities on ThinkOnward IT equipment and/or when connected to the ThinkOnward IT network may be monitored for legitimate business purposes.
All ThinkOnward Staff receive an access badge/fob which allows ThinkOnward to record the date, time and access points made by individuals within ThinkOnward premises and assets. The data from the access and security systems are used:
for health, safety and security purposes, to prevent fraud and specifically the protection of ThinkOnward assets, ThinkOnward and visitors to ThinkOnward premises;
to comply with legal and regulatory requirements, specifically where there is a local legal requirement to provide information to government/regulatory authorities;
to monitor (on an aggregated basis) the number of individuals entering and working in a ThinkOnward premise for human resources and real estate planning; and
in the case of contractors only (not ThinkOnward employees) the date and time of their entry and exit of ThinkOnward premises is used for the purposes of financial management and control.
ThinkOnward’s office is equipped with surveillance cameras (CCTV). Where surveillance cameras are used they will be identified. Surveillance cameras are used for health, safety and security specifically the protection of ThinkOnward assets, ThinkOnward staff and visitors to ThinkOnward premises. All images are routinely deleted unless there has been a health, safety or security incident, suspected or actual criminal activity, in which case they may be viewed by internal ThinkOnward investigation teams and externally if legally required or permitted by law enforcement or other government authority.
Screening
In order to comply with legal and regulatory obligations, to protect the Shell’s Group's assets and employees/contractors and specifically to ensure that the Shell Group, which includes ThinkOnward can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we carry out screening on all employees and contractors on a periodic basis. This screening takes place against publicly available or government issued sanctions lists and is compared with information held about you by Shell (for example from the Conflict of Interest register - see here for more information).
Any personal information collected through the screening will not involve profiling or automated decision making regarding suitability for continued employment, internship or engagement as a contractor.
Who is responsible for any personal information collected?
ThinkOnward LLC will be responsible for processing your personal information, either solely or jointly with its affiliates within the Shell group of companies or the relevant employing or engaging company within ThinkOnward.
Who will we share the personal information with?
Your personal information is exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:
Authorized third party agents, service providers, external auditors and/or subcontractors of Thinkonward; and
A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the relevant ThinkOnward company/companies is subject to or as permitted by applicable law; or
As necessary or appropriate to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and
Any person to whom ThinkOnward proposes to transfer any of its rights and/or duties.
8. Your personal information may be transferred outside of your country, subject to appropriate safeguards.
Transfers of your personal information to other countries
Where your personal information has been transferred to companies within ThinkOnward and/or to authorized third parties located outside of your country we take organizational, contractual and legal measures to ensure that your personal dainformationta is exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented to safeguard your personal information. These measures include Binding Corporate Rules for transfers among the Shell group and for Shell companies in the European Union, European Commission approved transfer mechanisms for transfers to third parties as well as any additional local legal requirements. You can find a copy of Shell Binding Corporate Rules at Privacy notices | Shell Global or by contacting privacy-office-SI@shell.com.
9. ThinkOnward is committed to safeguarding your personal information.
Security of your personal information
We have implemented technology and policies with the objective of protecting your privacy from unauthorized access and improper use and will update these measures as new technology becomes available, as appropriate.
How long do we hold your personal information for?
All information, including personal information, is managed in line with ThinkOnward standards for Information and Records Management and securely deleted thereafter.
Information contained within personnel files is held for no longer than 10 years once your employment has terminated;
information relating to retirement benefits are held for no longer than 99 years from the commencement of employment;
any personal information gathered as part of the screening against publicly available or government issued sanctions lists and media sources are held for no longer than 15 years after they were first gathered;
the names, date, time and access points for all individuals entering ThinkOnward premises are held for 3 years from each access;
where an individual has been dismissed or had their contract terminated due to serious misconduct, including breaching the Shell Life Saving Rules or breaching the Shell Code of Conduct that information is held for up to 30 years post termination.
In all cases information may be held for (a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or (b) a shorter period where you object to the processing of the personal information and there is no longer a legitimate business purpose to retain it.
Your rights in relation to your personal information
We aim to keep our information about you as accurate as possible. Any US resident, regardless of state of residency, can request the following:
access to your personal information, including access to specific pieces of personal information where local law applies;
correction or deletion of your personal information (but only where they are no longer required for a legitimate business purpose);
restriction and objection to the processing of your personal information under certain circumstances and where local law applies;
limit to the collection and use of your personal information, including sensitive personal information, for unrelated purposes where local law applies;
opt-out from the sale or sharing of your personal information, including for cross-context behavioral advertising or for targeted advertising, if sold or shared and where local law applies;
opt-out from the collection and use and/or to limit the disclosure or use of your personal information, including sensitive personal information, if collected and where local law applies;
to no longer receive marketing communications; and/or
that you receive personal information that you have provided to ThinkOnward, in a structured, digital form to be transmitted to another party, if this is technically feasible.
How to exercise your rights
For those individuals who have access to Insperity you can access your personal information through: https://insperity.com
Alternatively, please contact your local HR adviser. If you are a contractor, you should speak with your external contracting/employing company/agency. For former employees or dependents, please contact support@thinkonward.com.
Who can you contact if you have a query, concern or compliant about your personal information?
If you have any issues, queries or complaints regarding the processing of your personal information please contact your local HR contact.
You can also contact support@thinkonward.com.
Changes to this Privacy Notice
We reserve the right to update this Privacy Notice periodically and without notice, for example, when a new category of personal information is collected and used and upon changes/enactment of data protection and privacy laws. For significant or material changes to this Privacy Notice, we will prominently post such changes on this page and update the revision date to provide awareness. You are advised to regularly review this Privacy Notice for possible changes. This Privacy Notice was last updated in September 2025.