What does this Policy cover?
- sets out the types of personal data that we collect about you
- explains how and why we collect and use your personal data
- explains how long we keep your personal data for
- explains when, why and with who we will share your personal data
- sets out the legal basis we have for using your personal data
- explains the effect of refusing to provide the personal data requested
- explains the different rights and choices you have when it comes to your personal data
- explains how we may contact you and how you can contact us
What personal data do we collect about you?
We collect the information necessary to be able to find available opportunities and further information needed to assess your eligibility through the different stages of recruitment. This information includes CV’s, identification documents, educational records, work history, employment and references.
We may also collect sensitive personal data about you. We only collect sensitive personal data from you, and further process this data, where you have given your explicit consent.
Where do we collect personal data about you from?
The following are the different sources we may collect personal data about you from:
- Directly from you. This is information you provide while searching for a new opportunity and/or during the different recruitment stages [or coaching, where relevant].
- From an agent/third party acting on your behalf
- Through publicly available sources. We use the following public sources:
- Search Engines
- By Reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer.
How do we use your personal data?
We use your personal data to match your skills, experience and education with a potential employer. We will initially collect basic information on you such as contact details, job role and experience and then pass this on to the client in search of personnel. If you are chosen by the client and go through to the next stage, we will then be collecting more information from you at the interview (or equivalent) stage and onwards in that manner.
How long do we keep your personal data for?
We only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
When determining the relevant retention periods, we will take into account factors including:
- our contractual obligations and rights in relation to the information involved
- legal obligation(s) under applicable law to retain data for a certain period of time
- our legitimate interest where we have carried out a balancing test (see legal basis below)
- statute of limitations under applicable law(s)
- (potential) disputes
- if you have made a request to have your information deleted
- guidelines issued by relevant data protection authorities
Otherwise, we securely erase your information once this is no longer needed.
Who do we share your personal data with?
We share your personal data with the client who has a position to fill, in order to determine with the client whether you are a good fit for the available position. Our clients are spread across industry sectors and we provide senior and executive search to these clients on a retained basis. The majority of our clients are based in the EEA, but we do from time-to-time work with clients based outside of the region, including the USA and Australia.
We may also conduct checks on you to verify the information you have provided and where we do this we will ask you for your explicit consent and confirm the details of the verification company we will use.
We share your personal data internally with Partners, Associates, Researchers and Executive Assistants during the course of our search, recruitment and talent mapping projects.
What legal basis do we have for using your information?
For prospective candidates, referees and clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees. We carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to and can find out more about the information in these balancing tests by contacting us using the details below.
If you are shortlisted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case, we always ask for your consent before undertaking such processing.
For clients, we may also rely on our processing being necessary to perform a contract for you, for example in contacting you.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary, or withdraw your consent for the processing of your personal data, we may not be able to match you with available job opportunities.
Do we make automated decisions concerning you?
We do not carry out automated decision making and profiling.
We use statistics cookies which measure how often you visit our website and how you interact with it. These cookies do not collect any information that could identify you and are only used to help us improve how our website works, understand what interests our users and measure how effective our content is. They help us improve our users’ experience by collecting and reporting information anonymously and in no way give us access to your computer or any information about you, other than the data you choose to share with us.
Do we transfer your data outside the UK?
To better match your employee profile with current opportunities we may transfer your personal data to clients in countries outside the UK. These countries’ privacy laws may be different from those in your home country. Where we transfer data to a country which has not been deemed to provide adequate data protection standards we always have security measures and approved model clauses in place to protect your personal data.
We only transfer personal data outside the UK if the client and role we have been retained to fill is based outside the region. For example, if we are conducting a search for a position based in a region outside of the UK for an EEA based organisation.
To find out more about how we safeguard your information as related to transfers contact us on firstname.lastname@example.org
What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country
|Right||What does this mean?|
|1. The right to be informed||You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.|
|3. The right to rectification||You are entitled to have your information corrected if it’s inaccurate or incomplete.|
|4. The right to erasure||This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.|
|5. The right to restrict processing||You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.|
|6. The right to data portability||You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.|
|7. The right to object to processing||You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).|
|8. The right to lodge a complaint||You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.|
|9. The right to withdraw consent||If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.|
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
How will we contact you?
We may contact you by phone, email or social media. If you prefer a particular contact means over another please just let us know.
How can you contact us?
If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact us here:
25 Kingly Street
Our EU Representative
Under Article 27 of the GDPR , we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is :Instant EU GDPR Representative Ltd.
INSTANT EU GDPR REPRESENTATIVE LTD
12A Lower Main Street
Contacting the ICO
If you remain dissatisfied with how we’ve handled your personal data, then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:
Information Commissioner’s Office
11 August 2022