1. PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR) and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. ABOUT US
Clifton Global LLP (“Clifton Global”, “we”, “us”, “our” and “ours”) is a global executive recruitment firm. We are registered in England and Wales as company under number OC413795 and our registered office is at 1 Royal Exchange, London, EC3V EDG.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’ as well as the ‘data processor’. By a data controller we are responsible for deciding how we hold and use personal data about you. As a data processor we are responsible for processing data in relation to information or data obtaining, recording or holding your personal information or data. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
Our Co-Founding Partner, James Bailey, is the Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 12 (Contact Us), below.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, in order to provide our services, for example, when:
- we contact you to discuss potential opportunities;
- details resulting from our direct communication/interaction with you, such as notes or your submission of a CV/ relevant supporting information
- you request a proposal from us in respect of the services we provide;
- you contact us by email, telephone, post, or social media (for example when you have a query about our services);
- you OR your employer OR our client engages us to provide our services and also during the provision of those services;
- from third parties and/or publicly available resources (e.g. Linkedin, Google, Periodicals);
- from word of mouth, e.g. a friend, former employer, former colleague or current employer.
4. THE KIND OF INFORMATION WE MAY HOLD ABOUT YOU
The information we may hold about you can include the following:
- your personal details (such as your name, address, date of birth, employer, certain salary details, gender, nationality, employment history, degrees and other potential qualifications, languages and other skills);
- opinions or references (informal and formal from third parties);
- details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
- details of any services you have received from us;
- our correspondence and communications with you;
- information about any complaints and enquiries you make to us;
- information from research;
- information we receive from other sources, such as publicly available information or information provided by your employer;
- we strongly encourage you not to disclose any unnecessary sensitive information as we will only ever seek to utilize strictly relevant information in order to assist our services.
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may hold data which can include contact details and company information for purposes necessary for and to comply with our legal obligations. This may also include seeking your thoughts and opinions on the services we provide as well as notifying you about any changes to our services.
We do not carry out automated profiling for potential candidates and do not carry out automated decision making concerning your information.
If you refuse to provide us with certain information when requested, we may not be able to perform our services with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We may process your personal data for the purposes necessary for the performance of our contracts with our clients. This may include processing your personal data where you are a potential candidate to one of our clients.
We may process your personal data for the purposes of our own ‘legitimate interests’ as the data controller or processor, provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This is in order to align your skills experience and education with a potential employment opportunity. By providing Clifton Global with your personal data you acknowledge your interest and acceptance to share your information and have this securely stored by Clifton Global, so that when appropriate your candidacy can be considered for one of Clifton Global’s confidential executive searches.
On occasion Clifton Global may share strictly anonymized (always without the potential candidate or organisation’s name) biographical profiles of potential candidates, relevant to a specific assignment with our clients; demonstrating the most applicable candidates for said opportunity. Direct communication will always be made with candidates to obtain genuine interest and express permission to communicate an interest for a position with one of our clients. In addition, components of the personal information you may have provided us with (again strictly anonymized in its entirety) may be used in order for us to compile specific industry employment statistics.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Clifton Global uses your data to enable us to service your organization effectively; enhancing our deliverables and our wider relationship with you.
Referees and Sources
Clifton Global uses the data provided to us, to enable us to gather relevant opinions on the relevancy of certain potential candidates for mandates we are executing on behalf of our clients. Furthermore, your details may be used by us to make you aware of potential opportunities/ services we believe may be of interest.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected and where there are legitimate interests pursued by the controller or processor.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided;
- any statutory or legal obligations;
- the purposes for which we originally collected the personal data;
- the lawful grounds on which we based our processing;
- the types of personal data we have collected;
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
6. DATA SHARING
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us, where we have another legitimate interest in doing so. Regarding candidates, we may share your information with clients who may process your personal data in accordance with the purposes already outlined. In relation to referees and sources, we may share your information with potential candidates you may have proposed; all information being kept to a minimum level unless explicitly directed otherwise. In all other cases, we will not give out any information about you without your express consent.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, accountancy, foreign exchange, professional advisory services, administration services, travel agencies and banking services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business.
We may also need to share your personal data with a regulator or to otherwise comply with the law.
Your personal data will never be knowing sold to a third part by Clifton Global.
7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
We may transfer the personal data we collect about you to certain countries outside of the EEA in order to provide our services to you.
There is an adequacy decision by the European Commission in relation to these countries therefore they will be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.
Should you require further information about this, please contact us using the contact details outlined below.
8. DATA SECURITY
We have put in place commercially reasonable and 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 and other third parties who have a business need to know, detailed above. 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 data security breach and will notify you and any applicable authority of a suspected breach where we are legally required to do so.
9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully;
- Request correction of the personal data that we hold about you;
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below);
- 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 which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes;
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact James Bailey firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
10. RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our Data Protection Point of Contact, James Bailey at email@example.com
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
11. CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be updated on our website at:
This privacy notice was updated on 23rd May 2018.
12. CONTACT US
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact: James Bailey firstname.lastname@example.org
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time.
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