How do we collect personal data about you?
We collect information that you provide to us when you:
- Make an enquiry, provide feedback or any other interaction over the phone (including by SMS or other electronic messaging services), or by email;
- Submit correspondence to us by post, email, SMS or other electronic messaging services;
- Are or might be a prospective or actual candidate in the context of our executive search services;
- Register to and/or attend our events;
- Submit a CV or an application or attend an interview, or meeting whether on a speculative basis or in the context of a specific executive search assignment being undertaken by us; and
- Interact with our social media accounts, including LinkedIn.
Do we source any personal data from publicly available sources and/or from third party data vendors?
In certain circumstances, we will receive information about you from third parties. For example, from our clients, for example feedback about applications or interviews or from publicly available sources, including (but not limited to) company websites; LinkedIn; Bloomberg; newspapers and magazines. We do this to gather relevant information about your professional background in order to provide you and/or our clients with relevant information in relation to our executive search services.
What personal data are we collecting?
The information you provide to us may include (depending on the circumstances):
- Identity and contact data: title, names, addresses, email addresses and phone numbers, age, gender, nationality.
- Employment and background data relevant to our executive search services: in the process of executing our executive search services we may also collect information about your employment history, educational qualifications, compensation details, a record of our contact history with you and references from third parties.
We also collect the following information about you:
- Information contained in correspondence: we will collect any information contained in any correspondence between us. For example, if you contact us by email or telephone, we may keep a record of that correspondence.
Do we collect special category data?
What is the purpose of collecting your personal data?
We will use your information for the purposes listed below either on the basis of:
- Your consent (where we request it);
- Where we need to comply with a legal or regulatory obligation; or
- Our legitimate interests or those of a third party – where we refer to using your information on the basis of our “legitimate interests”, we mean our legitimate business interests in conducting and managing our business and our relationship with you as explained below.
- To conduct our executive searches: we collect your personal data in order to match you with a position with one of our clients (on the basis of our legitimate interest to provide a comprehensive executive search service to our clients). In the initial stages of a search, we may share basic data (typically your name and a brief employment and academic history), in order to provide the client with a summary of the most suitable candidates for the role in question.
- To introduce you to our clients who you have expressed an interest in you: before presenting further details about you to our clients, or indicating any potential interest you might have in a role with one of our clients, we would make direct contact with you to confirm your agreement to our sharing more detailed personal data.
- Social media interactions: to interact with users on social media platforms including LinkedIn and Twitter, for example, responding to comments and messages, posting and ‘liking’ posts (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals).
- Compliance with policies, procedures and laws: to enable us to comply with our policies and procedures and enforce our legal rights and share your information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).
What are your rights in relation to the personal data we hold?
Blakeney Search Limited treats all Personal Data in a manner consistent with the requirements of the UK GDPR and Data Protection Act 2018 and that of the EU GDPR. Blakeney Search takes reasonable steps to ensure personal data is accurate, up to date and complete for the purposes for which it is collected and used.
As a data subject you have the right to request access to the personal data that we have collected on you. This could be for the purpose of reviewing, modifying, or requesting deletion of the data. You also have the right to request a copy of the personal data we have collected about you. This Privacy statement confirms that Blakeney Search ensures that all our candidates and clients have the following rights with regards to the data that we hold on them;
- The right to be informed;
- The right of access;
- The right to rectification;
- The right to erase;
- The right to restrict processing;
- The right to data portability;
- The right to object;
- Rights in relation to automated decision making and profiling.
If you would like to make any requests with regards to your data held by Blakeney Search then please contact us at [email protected] where all queries will be dealt with in in a timely manner.
Depending upon the circumstances and the request, the Company may not be permitted to provide access to personal data or otherwise fully comply with your request; for example, where producing your information may reveal the identity of someone else. Data subjects have the right to know, from the data controller as to whether or not personal data concerning them is being processed, where and for what purpose, free of charge. However, we reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law should the request be deemed repetitive or excessive. Likewise, we reserve the right to deny your requests where, in the Company’s discretion, they may be unfounded, excessive, or otherwise unacceptable under applicable law.
We do not make recruiting or hiring decisions based solely on automated decision-making. All decisions regarding recruiting or hiring decisions are made by humans.
What lawful basis are we relying on to process your personal data?
How is your data kept secure?
Your personal data is stored in a secure and highly confidential database accessible only by Blakeney Search employees. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:
- Ensuring the physical security of our offices or other sites;
- Ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;
- Maintaining a data protection policy for, and delivering data protection training to, our employees; and
- Limiting access to your personal information to those in our company who need to use it in the course of their work.
When we disclose your personal data to clients and other 3rd parties, we request that that they undertake to protect the security and confidentiality of such information in accordance with applicable law.
Is any data stored or handled outside the EEA (European Economic Area)?
Our suppliers outside of the EEA
Some of our data is stored on secure cloud based servers, which are located within the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following transfer solutions are implement:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, European Commission: Model contracts for the transfer of personal data to third countries; and
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, European Commission: EU-US Privacy Shield.
Clients outside of the EEA
Please contact us using the contact details at the top of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Is your personal data shared with other organisations?
We may share your personal data with a client if we believe that you have the relevant experience and capabilities for a specific search that we are undertaking. In the initial stages of a search, we may share basic data (typically your name and a brief employment and academic history), in order to provide the client with a summary of the most suitable candidates for the role in question. If a client is interested in your possible candidacy, we will contact you directly. We will then, with your permission, share further details with them.
We may also share your personal data with the following third parties:
Our service providers:
- Hosting services based in the United Kingdom.
- IT, system administration and security services based in the United Kingdom.
- Legal, accountancy, auditing and insurance services and other professional advisers based in the United Kingdom.
Other third parties (including professional advisers): any other third parties (including legal or other advisors, regulatory authorities, courts, law enforcement agencies and government agencies) based in the United Kingdom where necessary to enable us to enforce our legal rights or where such disclosure may be permitted or required by law; and
What is our data retention policy?
Blakeney Search have variable data retention policies depending upon the type of personal data and whether both parties continue to do business together. Blakeney Search may nevertheless continue to retain and use your personal data for a period of 7 years (which may vary depending on the country) for system administration purposes, to consider you for potential future roles, and to perform research.
Our third-party data processors
Security and data breaches
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Should there be any breach of your personal data, we will inform you within 72 hours of knowing of it. We strive to ensure your personal information is protected at all times.