Executive Headhunters GDPR Privacy Policy

1.Introduction

1.1 Executive Headhunters EMA Partners UK (we or us) are committed to protecting the personal information and privacy of the candidates we represent and the clients for whom we work.

1.2 This Information Notice, together with any other documents referred to in it, sets out the basis on which any personal data that we collect from or about you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we treat it.

1.3 For the purpose of the General Data Protection Regulation, the data controller is Executive Headhunters Ltd (company number 05592776), whose registered office is at Stocks Court, 18-20 Old Market Place, Altrincham, Cheshire, WA14 4DF.

1.4 We may update this Information Notice from time to time. Any changes we make in the future will be posted on our website at www.executiveheadhunters.co.uk. Please check back regularly to see any updates or changes.

2.Data Protection Officer

2.1 The contact details for our Data Protection Officer are as follows:

2.1.1 Alison Ryan
2.1.2 Client Services Director
2.1.3 alisonryan@executiveheadhunters.co.uk
2.1.4 0207 160 6996
2.1.5 Stocks Court, 18-20 Old Market Place, Altrincham, Cheshire, WA14 4DF

2.2 It is the responsibility of the Data Protection Officer to keep our organisation and our staff informed and advised about their obligations to comply with data protection laws, to monitor compliance with those laws, to advise on data protection impact assessments, to train staff and conduct internal audits, and to be the first point of contact for supervisory authorities and for individuals whose personal data we are processing.

3.Particulars of processing

3.1 We process personal data about our stakeholders (by which we mean current and former candidates, clients and any other person who has contact with us) in a range of ways, and for a range of purposes.

3.2 he categories of person about whom we process personal data are described in more detail in the Particulars of Processing that are set out in the Schedules to this Information Notice. The specific Schedules are as follows:

3.2.1 Candidates;
3.2.2 Clients;

3.3 It may be the case that you have contact with us in more than one capacity, so please look at all the Schedules that may apply to you if you wish to know more about how we process your personal data.

4.You have the following rights:

4.2.1 The right to request access to the personal data that we hold about you;

4.2.2 The right to request rectification of the personal data that we hold about you;

4.2.3 The right to request erasure of the personal data that we hold about you;

4.2.4 The right to request restriction of processing about you;

4.2.5 The right to object to processing; and

4.2.6 The right to data portability.

If you wish to invoke any of the above rights, please notify our Data Protection Officer using the contact details set out in Section 2 above. Please include the words DATA PRIVACY REQUEST in the subject line of your email, or at the top of your letter.

4.3 Where our processing of personal data is based on your having given consent, you have the right as a data subject to withdraw that consent at any time. If you wish to invoke this right, please notify our Data Protection Officer using the contact details set out in Section 2 above. Please include the words DATA PRIVACY REQUEST in the subject line of your email, or at the top of your letter.

4.4 You have the right to lodge a complaint with a supervisory authority. In the United Kingdom, the supervisory authority is the Office of the Information Commissioner, full contact details for which can be found at https://ico.org.uk/global/contact-us/

5.Contact details

5.1 You can contact us in the following ways if you have any questions or concerns about personal data and privacy matters:

5.1.1 info@executiveheadhunters.co.uk
5.1.2 0207 160 6996
5.1.3 Stocks Court, 18-20 Old Market Place, Altrincham, Cheshire, WA14 4DF

5.2 Please include the words DATA PRIVACY REQUEST in the subject line of your email, or at the top of your letter.

Sample Particulars of Processing

Category of data subjectCandidates
Categories of personal data that we processName, address and other contact details
Date of birth
Nationality (and work permit details where relevant)
Academic history and qualifications
Career history, referee details and references
Salary and benefit entitlement
Purposes of the processingWe process the personal data listed above for the purposes of operating a recruitment service, providing services to both candidates and employers.
Lawful basis of processingThe lawful basis of processing is (a) that the processing is undertaken with the consent of the data subject, and/or (b) that the processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract.
Recipients of the personal dataThe personal data that we hold about candidates will be disclosed to prospective employers, where we have the specific permission of the candidate to such disclosure.

The personal data will be securely stored by Dillistone Systems Ltd , a company registered in England under company number 02043300 with its registered office at 50 Leman Street, London E1 8HQ, United Kingdom and trading as Filefinder. Filefinders’ services include the provision of software that allows search firms to store contact details and professional information for the search firms’ own candidates and clients. The storage is carried out under a written contract that includes safeguards for the rights and freedoms of data subjects.

Overseas transfersIf the role being applied for is based overseas, candidate information will be passed on to the overseas client with permission from the candidate
Duration of processingUnless the candidate consents to their information remaining on our database, personal data will continue to be processed for 1 year following a lack of active engagement
Is the provision of this personal data a statutory or contractual requirement, or a requirement necessary to enter into a contract?

If so, is the data subject obliged to provide the personal data in question?

What are the possible consequences of failure to provide such data?

You are not obliged to provide the personal data in question. However, if you do not provide the personal data, we may be unable to match your details up with potential employers.
Is there any automated decision-making done using the personal data (including profiling)?

If so, (a) what logic is involved, and what are the significance and envisaged consequences of the processing for the data subject?

During the process, candidates may be subject to psychometric profiling.
This profiling serves only to aid recruitment process, and ensure candidates and employers are matched correctly.
This profiling is not strictly required, however if candidates do not carry out the profiling process, we may be unable to match their details with potential employers and gauge their suitability for the role.
None of the profiling used is automated.
Plans for further processingUnless given permission by the candidate, no further processing will be carried out.
Category of data subjectClients
Categories of personal data that we processName, address and other contact details
Nationality (and work permit details where relevant)
Position in their company
Company information (name, industry, website, number)
Role being recruited for
Information on the role (salary range, desired candidates, etc)
Source of informationThe above personal data is received direct from the data subject.
Purposes of the processingWe process the personal data listed above for the purposes of operating a recruitment service, providing services to both candidates and employers.
Lawful basis of processingThe lawful basis of processing is (a) that the processing is undertaken with the consent of the data subject, and/or (b) that the processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract.
Recipients of the personal dataThe personal data that we hold about clients will be disclosed to prospective candidates, where we have the specific permission of the client to such disclosure.

The personal data will be securely stored by Dillistone Systems Ltd , a company registered in England under company number 02043300 with its registered office at 50 Leman Street, London E1 8HQ, United Kingdom and trading as Filefinder. Filefinders’ services include the provision software that allows search firms to store contact details and professional information for the search firms’ own candidates and clients. The storage is carried out under a written contract that includes safeguards for the rights and freedoms of data subjects.

Overseas transfersIf the candidates are located overseas, client information will be passed on to the overseas candidate with permission from the client
Duration of processingUnless the client consents to their information remaining on our database, personal data will continue to be processed for the duration of the replacement period, and 3 years following a lack of active engagement
Is the provision of this personal data a statutory or contractual requirement, or a requirement necessary to enter into a contract?

If so, is the data subject obliged to provide the personal data in question?

What are the possible consequences of failure to provide such data?

You are not obliged to provide the personal data in question. However, if you do not provide the personal data, we may be unable to match your details up with potential candidates.
Is there any automated decision-making done using the personal data (including profiling)?No.
Plans for further processingUnless given permission by the candidate, no further processing will be carried out following the end of the replacement period.

6. Our Use of Cookies

  1. Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
  2. By using Our Site, you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third Party Cookies are used on Our Site to allow our website to present you with customised Web pages and to also track which pages you may have visited. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
  3. All Cookies used by and on Our Site are used in accordance with current Cookie Law.
  4. Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
  5. Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 6.7, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
  6. The following Cookies may be placed on your computer or device:
    Name of CookiePurposeStrictly Necessary
    __hstcThe main cookie for tracking visitors. It contains: the domain, utk (see below), initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session)Yes
    hubspotutkThis cookie is used for to keep track of a visitor’s identity. This cookie is passed to HubSpot on form submission and used when deduplicating contacts.Yes
    __hsscCookie for keeping track of sessions. This is used to determine if we should increment the session number and timestamps in the __hstc cookie. It contains: the domain, viewCount (increments each pageView in a session), session start timestamp.Yes
    __hssrcWhenever HubSpot changes the session cookie, this cookie is also set. We set it simply to the value “1”, and use it to determine if the user has restarted their browser. If this cookie does not exist when we manage cookies, we assume it is a new session.Yes
    __hs_opt_outThis cookie is used by the opt-in privacy policy to remember not to ask the user to accept cookies again. This cookie is set when you give users the choice to opt out of cookies.Yes
    __hs_do_not_trackThis cookie is set when you give users the choice to opt out of cookies and they choose to do so. It disables tracking and personalization.Yes
    __hs_testcookieThis cookie used to test whether the visitor has support for cookies enabled.Yes
    hsPagesViewedThisSessionThis cookie used to keep track of page views in a session.

     

  7. In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
  8. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
  9. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

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