What does this policy cover?
We at Stephenson Executive Search take your personal data seriously. This policy:
- 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; and
- 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 CVs, identification documents, educational records, work history, employment and references.
We may also collect sensitive personal data about you. Sensitive Personal Data includes: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sex life and sexual orientation, genetic and/or biometric data. 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.
- Through publicly available sources, such as LinkedIn
- By Reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or a present employer.
How do we use your personal data?
We use your personal data in when:
- Handling an executive search assignment. If we believe you are suitable for a specific role, we may pass your basic details on to the relevant client. If that client agrees that you might be suitable, we will then discuss this with you in more detail. You might be interviewed for the role by one of our Headhunters. If successful, you might be shortlisted for interview by our client. At this point, we will pass further details to the client and you may receive further direct correspondence from them.
- From time to time, we conduct mapping or research exercises on behalf of our clients. This is to enable them to understand a particular market. Here, we may include certain aspects of your personal data. You will not be contacted by any third party about this unless we first obtain your consent.
- We will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others or, have your permission to do so.
Please be aware that we are not responsible for the data processing activities of others, such as our clients.
We will use client data to perform our services to you and other legitimate business purposes such as marketing.
Source and Referee
We will use source and referee data to perform our services, in particular, to enable us to obtain your opinions on a candidate.
We may also use this information to enable us to market our services to you as a potential client. We may also invite you to become a candidate in respect of the provision of our services.
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:
(a) our contractual obligations and rights in relation to the information involved;
(b) legal obligation(s) under applicable law to retain data for a certain period of time;
(c) our legitimate interest where we have carried out a balancing test (see legal basis below);
(d) statute of limitations under applicable law(s);
(e) (potential) disputes;
(f) if you have made a request to have your information deleted; and
(g) guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information where we no longer require your information for the purposes collected.
Who do we share your personal data with?
We share your personal data with our clients, for whom we provide executive search services in the financial services sector. For prospective clients, we might need to demonstrate an understanding of a particular sector and the individuals that work in it.
What legal basis do we have for using your information?
For 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 this 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?
No, we do not carry out automated profiling.
Do we transfer your data outside the EEA?
No, we do not transfer personal data out of the EEA.
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.
|Rights||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 are providing you with the information in this Policy.|
|3. The right to rectification||You are entitled to have your information corrected if it is inaccurate or incomplete.|
|4. The right to erasure||This is also known as ‘the right to be forgotten’ and enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it.|
|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.|
|7. The right to object to processing||You have the right to object to certain types of processing.|
|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.|
|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.|
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.
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 have handled your information, or have further questions on the processing of your personal data, contact at 54 South Molton Street, London W1K 5SG, firstname.lastname@example.org.