Privacy Policy
This Privacy Policy tells you how we look after the personal data that we collect about you, what we do with that data, and how we protect it.
The Hogarth Davies Lloyd Group is made up of different legal entities which are:
– HDL Executive Search LLP (in the UK)
– HDL NY L.P. (in the US)
– HDL Executive Search Pte. Ltd. (in Singapore)
This Privacy Policy is issued on behalf of the Hogarth Davies Lloyd Group, so when we mention “we”, “us” or “our” in this Privacy Policy we are referring to the relevant entity in the Hogarth Davies Lloyd Group responsible for processing your data (see section 1 below).
It is important that you read this Privacy Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This Privacy Policy is provided in a layered format, so you can click through to the specific areas set out below.
Important information and who we are
Controller
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.
We have appointed a data protection officer (DPO) to oversee any queries about this Privacy Policy. If you have any such queries, including any requests to exercise your legal rights in relation to your personal data, please contact the DPO using the following details set out below:
Email address: [email protected]
Postal address: Data Protection Officer, Hogarth Davies Lloyd, 3 St James’s Square, St. James’s, London, SW1Y 4JU, 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.
Informing us of changes
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.
Third-party links
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.
The data we collect about you
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:
Candidate data
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:
– contact information such as your first name, last name, title, date of
birth, gender, email address, telephone number(s) and home
address;
– profile information such as your qualifications, work history,
experience, skills, achievements, references, accreditations, work
preferences, salary expectations and career goals;
– additional information that you choose to tell us; and
– additional information that our clients may pass on to us, or that we
may collect from other sources (e.g. from your referees, or from
professional networking sites).
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).
Client data
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.
If you fail to provide personal data
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.
How we collect your personal data
Candidate data
We mainly collect this from our direct interactions with you, including when you:
– speak with us on the phone;
– provide us with your CV or application information;
– send us emails; or
– meet with us face-to-face (or, for example, via video-conferencing).
We may also collect personal information about you from other sources, including:
– from our clients;
– from your referees;
– from publicly-available, online sources (e.g. professional networking
sites such as LinkedIn); or
– by word-of-mouth.
Client data
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.
How we use your personal data
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:
– speak with us on the phone;
– provide us with your CV or application information;
– send us emails; or
– meet with us face-to-face (or, for example, via video-conferencing).
We may also collect personal information about you from other sources, including:
– to contact our clients to discuss new briefs and positions to be filled;
– to contact potential candidates to discuss their interest in, and
suitability for, positions;
– to collect personal information from candidates, referees and from
other sources;
– to share information about candidates with clients, in order to assess
the suitability of potential candidates and whether they are a good
fit for a particular role;
– to request and obtain additional personal information from
candidates that may be required for a particular role or position;
– to discuss with clients and candidates how the recruitment process is
progressing;
– to support candidates through the interview and appointment
process; and/or
– to share information about candidates and clients with other entities
in the Hogarth Davies Lloyd Group, for the above-mentioned
purposes, where there is a possible international dimension to a
particular position or candidate.
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.
For the performance of a contract
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.
With consent
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.
Where we need to comply with a legal or regulatory obligation
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.
Change of purpose
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.
Opting out
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.
Disclosures of your personal data
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:
– Our clients (e.g. who may be interested in considering a potential candidate for a position).
– Other third parties, where reasonably necessary to verify a candidate’s identity and the information they have provided (e.g. referees).
– Other entities within the Hogarth Davies Lloyd Group.
Client Data may be shared with:
– Potential candidates (e.g. after a client has told us that they would like us to share the client’s identity and/or contact details with a potential candidate).
– Other entities within the Hogarth Davies Lloyd Group.
Candidate Data or Client Data may also be shared with certain other third parties such as:
– Service providers who help us to fulfil our contractual obligations and to operate our business (e.g. by providing IT and system administration services).
– Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
– Taxation authorities, regulators and other authorities who require reporting of processing activities in certain circumstances.
– Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
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.
International Transfers
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:
– transferring your personal data to a country, organisation or sector that has, at the time of transfer, been deemed to provide an adequate level of protection for personal data by the European Commission;
– using specific forms of contract approved by the European Commission that give personal data the same protection it has within Europe; and/or
– transferring data to a provider based in the US if such provider is part of the Privacy Shield, which requires it to provide similar protection to personal data shared between the Europe and the US.
For further details of such safeguards, please see the European Commission’s website.
Data Security
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.
Data Retention
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.
Your legal rights
Under certain circumstances, you may have the following rights under data protection laws in relation to your personal data:
– Right of access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing such data.
– Right of rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data that you provide to us.
– Right to erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for our continuing to process such data. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
– Right to restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you would like us to establish the accuracy of such data; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
– Right to portability of your personal data to you or to a third party. If you so request, we shall provide you, or a third party that you have chosen, with a copy of your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
– Right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you believe that it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
– Right not to be subject to automated decision-making (including profiling) where that would have a significant effect on you. We do not in fact engage in such activities, so this right will not, in practice, be relevant.
– Right to withdraw consent at any time where we are relying on consent to process your personal data. This will not, however, affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We shall inform you if that is the case at the time when you withdraw your consent.
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.
No fee usually required
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.
What we may need from you
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.
Time limit to respond
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.
Cookies policy
Our website at www.hogarthdavieslloyd.com is operated by HDL Executive Search LLP.
We do not set cookies on our website, nor do we collect, use or store any personal information about visitors to our website. If we set cookies in the future, we will update this Cookies Policy accordingly.
Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics measures how users interact with our website content through the use of tracking cookies. As a user navigates between web pages, Google Analytics provides our website with tags to record information about the page a user has seen, such as the page URL, time and date of visit, length of visit, country of residence and language settings.
The information generated by Google’s cookies about your use of the website (including your IP address) is anonymous and will be sent to Google and held on Google’s servers in the USA in accordance with Google’s privacy policy (available at http://www.google.co.uk/intl/en/privacy/). Please note that Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You can find out more information on how Google uses cookies at: http://www.google.com/intl/en/policies/technologies/cookies/
By continuing to use our website, you acknowledge our use of web analytics.
Changes to our privacy policy
We may at any time update or otherwise modify this Privacy Policy. We will notify you of any changes to our Privacy Policy by posting the modified Privacy Policy on the Site.
This version was last modified April 2021.