WHO ARE WE?
OUR COMMITMENT TO PRIVACY
WHAT INFORMATION DO WE COLLECT?
We collect and store the information which you give us via forms (such as our Enquiry Form) and via your CV, submitted either through our website or via email, telephone, social media or job post. The information contained within your CV and our Enquiry Form is classed as ‘Personal Information’. Personal information is any information about you as an identiﬁable individual and can include your name, email address, postal address, age, gender, income, marital status, health, current employment and compensation package, and previous employment history and compensation package, together with your personal references and identiﬁcation numbers (such as a National Insurance number).
WHAT DO WE DO WITH YOUR PERSONAL INFORMATION?
EslingKenny will only use your information for the purposes stated and for which you have given us your consent. Either before or when we collect personal information, we will explain how we intend to use it. We will limit the personal information we collect to what we need for those purposes, and we will use it only for those purposes. We will seek your consent if we wish to use your personal information for any other purpose.
We use your personal data to provide our recruitment services, which are primarily the arrangement of introductions/ placements between our clients and candidates but can include other services such as providing industry data and updates.
As a candidate our placement services will include:
- Candidate searching via social media (e.g. LinkedIn)
- Sending you job alerts which may be of interest to you/ keeping up to date
- Sending your CV and other personal data to clients who may be interested in employing you or contracting for your services (with your consent)
- Communicating with third parties (e.g. EslingKenny clients and candidates) to ﬁnalise and manage a placement
If you are a client, then we will communicate with you in order to deliver our services, ﬁnalise and manage a placement and collect and enforce payment.
We use your personal data to help us communicate with you effectively should you try to contact us via our site.
We may use your personal data to send you marketing emails (or other communications) with details of our services which may be of interest to you including information about new opportunities or keeping in touch. At EslingKenny we aim to build close and long-lasting partnerships with candidates and clients alike through regular and honest communication. If you do not want us to use your data in this way, then please contact us at firstname.lastname@example.org or reply advising you wish to unsubscribe when you receive such emails.
We retain personal data from closed accounts (completed permanent appointments) in order to comply with legal obligations, enforce our terms and conditions, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations and take other actions as permitted by law.
We may access, remove, alter or store or otherwise use any personal data if we think you have or may have breached our terms and conditions or to enforce our rights or protect the public or where if we are required to do so by law or appropriate authority.
We will not pass your personal data to companies outside of our group for marketing purposes, without your consent.
WHAT IS ‘PROCESSING’?
‘Processing’ includes the obtaining, recording or holding of information or data or carrying out any operation or set of operations on the information or data, including organising, altering, retrieving, consulting, using, disclosing, combining, or destroying the information or data.
For example, on receipt of your CV we may transfer it into our CV template and anonymise some of your personal information; e.g. we will remove your home address, telephone number and email address. We will not alter any content such as your career history or experience (without your explicit permission).
WHO DO WE GIVE YOUR PERSONAL INFORMATION TO?
As part of providing recruitment services to you we will submit your CV and other Personal Information to our clients as appropriate. We will obtain your consent before submission to each client separately should you wish to apply for more than one role (please see section on CONSENT below).
We do not rent or sell your personal information to anyone under any circumstances.
We may process your personal information for our legitimate business interests e.g. direct marketing, data analytics and/or enhancing/modifying/improving our services (see ‘Legitimate Interests’ section below).
We do not transfer any information, personal or otherwise, outside of the EEA (European Economic Area); unless speciﬁcally for an international vacancy, where we will seek your consent.
Under certain circumstances we may be required to disclose your personal information in response to valid requests by public authorities such as the Police or security services as required by law.
HOW DO WE PROTECT YOUR INFORMATION?
We use appropriate technical, organisational and administrative security measures to protect any information we hold from loss, misuse, unauthorised access, disclosure, alteration and destruction. Unfortunately, no company or service can guarantee complete security. Unauthorised entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.
HOW CAN YOU ACCESS THE PERSONAL INFORMATION WE HOLD ABOUT YOU?
We will give you access to the personal information we retain about you and will provide you with the opportunity to update the personal information we retain to ensure it is accurate. You can request a copy of the personal information that EslingKenny holds about you and to have any inaccuracies corrected. Please address requests to email@example.com.
We will provide you with a readable copy of the personal data which we keep about you, within a week – although we may require proof of your identity before release. We will provide the information without any charge.
We allow you to challenge the data that we hold about you and, where appropriate, you may have the data erased, rectiﬁed or amended, or completed.
If you would like to have whatever information we hold on you erased, please email us your instruction to firstname.lastname@example.org
ESLINGKENNY AND GDPR
In May 2018 new regulations concerning the collection, storage and retention of personal information will come into place. At EslingKenny we take your privacy seriously and have reviewed our existing processes, storage and retention of your personal information in light of this new legislation and as part of our ongoing commitment to your privacy. As a result, we have reviewed the purposes of our processing activities and selected the most appropriate lawful basis (or bases) for each activity.
OUR LEGAL BASES FOR PROCESSING YOUR DATA LEGITIMATE INTERESTS
Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."
We don't think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service which beneﬁts candidates and clients alike.
However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please contact us at email@example.com
We think it's reasonable to expect that if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our vacancies. Once it's looking like you may get the job, your prospective employer may also want to double check any information you've given us (such as the results from psychometric evaluations or skills tests) or to conﬁrm your references, qualiﬁcations and criminal record, to the extent that this is appropriate and in accordance with local laws. We need to do these things so that we can function as a proﬁt-making business, and to help you and other candidates get the jobs you deserve.
We want to provide you with tailored job recommendations and relevant articles to read to help you on your job hunt. We therefore think it's reasonable for us to process your data to make sure that we send you the most appropriate content.
We must make sure our business runs smoothly, so that we can carry on providing services to candidates and clients. We therefore also need to use your data for our internal administrative activities, like payroll and invoicing where relevant.
We have our own obligations under the law, which it is a legitimate interest of ours to insist on meeting. If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.
To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to undertake a customer satisfaction or NPS (Net Promoter Score) survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing executive search services to you and enabling our own continuous improvement.
In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. For example, we will always seek your consent before sending your CV to a client either speculatively or for a speciﬁc role.
Article 4(11) of the GDPR states that (opt-in) consent is "any freely given, speciﬁc, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signiﬁes agreement to the processing of personal data relating to him or her." In plain language, this means that:
- you must give us your consent freely, without us putting you under any type of pressure;
- you must know what you are consenting to – so we'll make sure we give you enough information;
- you should have control over which processing activities you consent to and which you don’t; and
- you need to take positive and affirmative action in giving us your consent – we're likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion or request email conﬁrmation.
We will keep records of the consents that you have given in this way.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for proﬁling your suitability for certain roles), or consent to market to you, you may withdraw your consent at any time. To withdraw your consent please email us at firstname.lastname@example.org
ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS
Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity".
This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
When you visit our web pages, something called a ‘cookie’ will be downloaded to your computer. Many websites do this, because the cookies provide non-personal statistical information about what people do on our website. For example: the time spent viewing a page, browser settings and other general information. We may use this data to improve the services on our site and to reﬁne the experience of those visiting our website. For more general information about cookies you can visit: www.allaboutcookies.org
WHAT IF I HAVE QUESTIONS ABOUT THIS POLICY?
If you have any questions or concerns regarding our privacy policies, please send a detailed message to email@example.com outlining details of your enquiry.