The Hogarth Davies Lloyd Group is made up of different legal entities which are:
The controller of your personal data is the relevant Hogarth Davies Lloyd Group entity that provides its executive search services to you, or that collects personal data about you in relation to its services.
Email address: [email@example.com]
Postal address: Data Protection Officer, Hogarth Davies Lloyd, 20-23 Holborn, London EC1N 2JD, United Kingdom
You have the right to make a complaint at any time to your supervisory authority for data protection issues. In the UK, this is the Information Commissioner’s Office (ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The Site and our other communications with you may contain links to other online or mobile sites. We are not responsible and accept no liability for the privacy practice or content of such sites.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e. anonymous data).
In the course of providing our services, we may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
This is the personal data we collect about candidates and potential candidates in order to offer employment opportunities suitable to your experience and interests, and which may include:
Candidate Data may also include personal data about other people that a candidate has provided to us (for example, the name and contact details of referees).
This is the personal data that we collect about our clients (or potential clients) and the individuals that work for them, which is generally limited to the contact information we need so that we can effectively provide our services, such as first name, last name, contact email address, and telephone number(s).
We do not typically seek to collect any Special Categories of Personal Data about you. This would include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we typically seek to collect any information about criminal convictions and offences. We will only collect such special data or information about candidates (and treat it as Candidate Data) if this is appropriate in accordance with local laws and is required for a particular role, or the type or role, that you are interested in (e.g. any necessary health-related information, or details of criminal convictions). We will only process such information with your explicit permission. You may withdraw that permission at any time by contacting us.
Where we need to collect personal data by law, or in order to provide our services, and you fail to provide that data when requested, then we may not be able to perform those services, or perform the contract that we have entered into (or are trying to enter into) with you. If so, we shall notify you if that is the case at the time.
We use different methods to collect personal information from and about you, including those methods set out below.
We mainly collect this from our direct interactions with you, including when you:
We may also collect personal information about you from other sources, including:
We collect this when we initially discuss with you whether you would like to engage us to provide our services to you, and then throughout the duration of our relationship.
We may also collect this information from publicly-available sources (such as from company websites) as part of our marketing activities, so that we can tell potential new clients about the services we can offer them.
We only use your personal data when the law allows us to. Most commonly we shall use your personal data on the following legal grounds:
Because it is necessary for our legitimate interests (or those of a third party)
When we collect and process Candidate Data or Client Data in relation to our services we do so because it is necessary in our interests as a provider of executive search services to be able to identify and match potential candidates to roles and opportunities in an efficient and effective way. It is also in the interests of potential candidates that we are able to offer them access to new opportunities that are tailored and targeted to their experience and interests, and to facilitate the recruitment process. Equally, it is in the interests of our clients that we are able to fill their vacancies with the best possible candidates available. Some of the purposes for which we may use information on this basis include:
We may also process personal data for our general marketing purposes, as it is necessary for our legitimate interests as a profit-making organisation to make both candidates and potential clients aware of the services we may be able to provide to them.
Whenever we process personal data in our legitimate interest we will always do so having considered your interests, and your fundamental rights and freedoms, and we will not process your personal data if those outweigh our legitimate interests (unless we have your consent or are otherwise required or permitted to by law).
If you have any objection to our processing of your data, or you have any queries at all about our use of your data, then please contact us using the information given at the beginning of this policy.
We also process Client Data in order to perform the contracts that we have entered into with a client (i.e. to provide our executive search services), or where we are taking steps prior to entering such a contract with a potential new client.
Generally we do not rely on your consent for processing your personal data other than in relation to any special categories of personal data (or criminal offence or conviction information) that you provide to us in a particular context (as described at section 2 above). You have the right to withdraw consent to us using that data/information at any time by contacting us.
We may also process your personal data where we need to do so to comply with a legal or regulatory obligation.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
If, at any time, you would like us to stop using your personal data or to correct any factual inaccuracies, just you can contact us by email or post.
We may share your personal data with the parties below, for the purposes set out in section 4 above.
Candidate Data may be shared with:
Client Data may be shared with:
Candidate Data or Client Data may also be shared with certain other third parties such as:
We require all such third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In the course of providing our services, you acknowledge that we may share your personal data with other entities in the Hogarth Davies Lloyd Group. You also acknowledge that, in order to provide our services effectively, we may, where relevant, also need to share your data with third parties (e.g. with potential employers) in various countries around the world.
For our candidates and clients in the European Union, this may involve transferring your data outside the European Economic Area (EEA). By submitting your personal data to us, you do so on the understanding that territories outside the EEA may provide a lower standard of protection for your personal information, and so there may not be adequate safeguards in place to protect your information, and you acknowledge that we may share your data with international recipients in this way.
We may also share data with international recipients where we are permitted to do so by law, in which case we will ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
For further details of such safeguards, please see the European Commission’s website.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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).
Given the nature of our business, it is common for candidates to remain in a job position for a significant period time before they are ready to move on to a new role. In order for us to fulfil our purpose of being able to offer opportunities to potential candidates at the right time, we may hold on to Candidate Data for a period of no longer than ten years following our last point of contact, unless we specifically obtain specific consent to retain it for longer (which consent can then be withdrawn at any time by contacting us).
In some circumstances you can ask us to delete your data: see Right to erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you may have the following rights under data protection laws in relation to your personal data:
To find out more about these rights, please see the ICO’s website (www.ico.org.uk).
If you wish to exercise any of those rights, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in those circumstances.
We may need to request specific information from you to help us confirm your identity and to ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data are not disclosed to any person that has no right to receive such data. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we shall notify you and keep you updated.
Our website at www.hogarthdavieslloyd.com is operated by HDL Executive Search LLP.
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This version was last modified May 2018.