What does this policy cover?
Our legal obligations regarding your Personal Data
We will collect and process your Personal Data in accordance with applicable laws that regulate data protection and privacy. This includes, without limitation, the EU General Data Protection Regulation (2016/679) ('GDPR') and the UK Data Protection Act 2018 ('DPA') together with other applicable UK and EU laws that regulate the collection, processing and privacy of your Personal Data (together, 'Data Protection Law'). We are responsible as 'controller' of your Personal Data for the purposes of Data Protection Law.
What Personal Data will we collect?
We may collect and use the following Personal Data about you:
- your name, contact details (including your email address and telephone number)
- details of your current role, responsibilities and remuneration
- details of your qualifications, previous work experience and historic remuneration
- opinions about your professional performance and suitability for vacancies
- your career plans
- details of your online professional profile (e.g. LinkedIn profile)
- details of your contact history with us (including call or meeting notes and records of messages by text or messaging service)
- your contact with our clients arranged by us and details of contact you have had with potential employers (other than as arranged by us)
- your nationality and immigration status
- your image
- your referees
- testimonials or comments you have provided about our services.
and other Personal Data that you may provide to us from time to time, including during recorded calls.
Please also note that some of the Personal Data you supply and that we process may include what is known as 'sensitive' data about you, for example, information regarding your health or ethnic origin.
If you choose not to provide the Personal Data we request, it may delay or prevent us from responding to a request or query, or providing our services to you.
How your Personal Data is collected
We collect most Personal Data directly from you during your relationship and communications with us by telephone (our calls may be recorded), email, text, messaging service or in person. However, we may also collect information:
- from publicly accessible sources e.g. LinkedIn, the corporate website of your employer;
- directly from third parties e.g. colleagues, former colleagues, former employers, acquaintances or referees;
- your former university or other education provider;
- if applicable your relevant professional body;
How and why we may process your Personal Data
We may use your Personal Data in the following ways:
- To answer your questions and enquiries
- To assess your Personal Data in order to assess your suitability for vacancies which we hope to fill for our clients
- To provide our services to you, including preparing and submitting your CV and other necessary Personal Data for vacancies and taking steps to progress your application, including arranging interviews and assessments, and keeping you updated on the progress of your application
- To enable to assess and improve our customer service and to make our services more valuable to you (including tailoring our website and our group companies' websites when you log on to make enrich your personal online experience)
- To conduct market research and background research as may be within out legitimate interests as an executive search company, to identify potential candidates who be suitable for roles with our clients, and to contact such candidates to discuss the requirements further
- To record the results of our research and our relationship and communications with you
- Where you have given your consent, for us to publish testimonials and comments about our services
- To provide you with direct marketing communications about what we are doing as well as our services (permanent, temporary, contract, outplacement and recruitment process outsourcing services), reports, offers, networking and client events and general information about the industry sectors which we think might be of interest to you by post or phone. If required under applicable law, where we contact you by SMS, email, social media and/or any other electronic communication channels for direct marketing purposes, this will be subject to you providing your express consent. You can object or withdraw your consent to receiving direct marketing from us at any time, by contacting us using the email address below.
From time to time we may seek your consent to process, use or disclose your information for another purpose not listed above.
The lawful grounds on which we collect and process your Personal Data
We process your Personal Data for the above purposes relying on one or more of the following lawful grounds:
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party;
- where you have given consent; or
- to comply with our legal and regulatory obligations.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Our legitimate interests include continuing to operate our executive search business, the administration and maintenance of records, management of client and candidate relationships, improvement of our services, and marketing our services.
If we process sensitive data as referred to above we will only do this with your explicit consent; or, where needed to comply with applicable social security or social protection laws; or, to protect your vital interests (or those of someone else) in an emergency; or, where you have already publicised such information; or, where we need to use such sensitive data in connection with a legal claim that we have or may be subject to.
Who we share your Personal Data with
We may need to disclose your Personal Data to certain third party organisations who processing Personal Data only in accordance with our instructions under contract (called 'data processors') such as companies and/or organisations that act as our service providers or professional advisers, or otherwise assist us in delivering the services that you have requested e.g. cloud storage providers and IT service providers.
We only allow our data processors to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data. We also impose contractual obligations on data processors to ensure they can only use your Personal Data to provide services to us and to you.
We may also disclose your Personal Data to third parties who make their own determination as to how they process your Personal Data and for what purpose(s) (called 'data controllers') e.g. if we submit your CV to a client, they will become a data controller in respect of the CV.
The third party data controllers external to us (including our clients) with whom we deal will handle your Personal Data in accordance with their own chosen procedures and you should check the relevant privacy policies of these companies or organisations to understand how they may use your Personal Data. Since they are acting outside of our control, we have no responsibility for the data processing practices of these data controllers.
We may also pass your information to, or allow access to such information to the Execuzen group of companies, whose locations can be found at www.execuzen.com who may use your Personal Data in the same way as we process, use and disclose your Personal Data as described above.
We may disclose and exchange information with regulatory or law enforcement agencies if we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings.
In all cases we always aim to ensure that your Personal Data is only used by third parties for lawful purposes and in compliance applicable Data Protection Law.
The Personal Data that we collect may be accessible by other Execuzen group companies, clients, and the third parties located outside of the European Economic Area (the 'EEA'). Accordingly, your Personal Data will be sent to or be capable of being accessed from outside the EEA in a territory whose laws are not considered to meet the standards for protection of Personal Data as are set out in Data Protection Law.
When we transfer your Personal Data outside the EEA, we will do so only under a contract or another appropriate mechanism which is authorised under Data Protection Law. This is to make sure that your Personal Data is safeguarded in accordance with the same legal standards that apply to us in the United Kingdom.
How do you find out what information we hold? Can you amend, modify or request this information be deleted, and can you unsubscribe from our services?
In accordance with your legal rights under Data Protection Law, you have a 'subject access request' right under which can request information about the Personal Data that we hold about you, what we use that Personal Data for and who it may be disclosed to as well as certain other information. Usually we will have a month to respond to such a subject access request, but we may, in case of complex requests, require a further two months to respond.
We reserve the right to verify your identity if you make a subject access request. We may also require further information to locate the specific information you seek before we can respond in full and apply certain legal exemptions when responding to your request. We may charge for administrative time in dealing with any manifestly unreasonable or excessive requests for access.
Under Data Protection Law you also have the following rights, which are exercisable by making a request to us in writing:
- to be provided with a copy of your Personal Data;
- to require us to correct Personal Data that we hold about you which is inaccurate or incomplete;
- to require us to erase your Personal Data without undue delay if we no longer need to hold or process it;
- to object to our use of your Personal Data for direct marketing (you may request to unsubscribe from job alerts and marketing material at any time. If you wish to contact us with respect to the above matters please email us at email@example.com);
- to object and/or to restrict the use of your Personal Data for purpose other than those set out above unless we have an overriding legitimate reason for continuing to use it; or
- to object to any automated processing (if applicable) that we carry out in relation to your Personal Data;
- in certain circumstances, to require us to transfer Personal Data to another party where the Personal Data is being processed by automated means.
All of these requests may be forwarded on to a third party provider who is involved in the processing of your Personal Data on our behalf.
If you would like to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
If you make a request and are not satisfied with our response, or believe that we are illegally processing your Personal Data, you have the right to complain to the Information Commissioner's Office (ICO) – see https://ico.org.uk/.
How long will we hold your information for?
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Please inform us of any changes to your Personal Data to ensure that it is up to date and we will update or erase the details we hold accordingly.
Sending us information over the internet
We employ appropriate technical and organisational security measures to protect your Personal Data from being accessed by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. However, the nature of the internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet.
How we collect and aggregate information about visitors to our websites
We also collect information about the way jobseekers and visitors use this website in order to improve our services. We do not use information gained in this way in a way that any individual can be identified, and only use it to understand our users better, and to determine aggregate trends, most popular pages, etc, for all the website’s users. We may share this kind of aggregate data with selected third parties to assist with these purposes. We may also undertake marketing profiling to help us identify services or jobs which may be of interest to you.
A cookie is a small data file which is sent from a web server to a web browser when that browser visits the server’s site.
Cookies are used on our website to remember your login to track web traffic on an aggregate basis (i.e. no individuals are identified), to track campaigns and to keep session information such as your last search. Most browsers allow you to turn off cookies. However, switching off cookies will likely restrict your use of our website.
Telephone: +44 207 245 8898