Harrison James Executive Privacy Policy
Harrison James Executive Ltd, Audrey House, 16 – 20 Ely Place, London EC1N 6SN, gdpr@hjexecutive.com, 0207 070 3010.
We provide Executive Search, Interim Management and Market Mapping services to clients looking to recruit personnel for their businesses.
This policy:
- sets out the types of personal data that we collect about you;
- explains how and why we collect and use your personal data;
- explains how long we keep your personal data for;
- explains when, why and with who we will share your personal data;
- sets out the legal basis we have for using your personal data;
- explains the effect of refusing to provide the personal data requested;
- explains the different rights and choices you have when it comes to your personal data; and
- explains how we may contact you and how you can contact us.
What personal data do we collect about you?
Candidates
We collect the information necessary to be able to find available opportunities and further information needed to assess your eligibility through the different stages of recruitment. This information includes CVs, identification documents, educational records, work history, employment and references, Limited company information, contact details and salary information.
Clients
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 correspondence, meetings, registered jobs and placements.
Referees or Emergency Contacts
To ensure we can provide candidates with suitable employment opportunities safely and securely and to provide for every eventuality for them and our staff, we need some basic background information. We only ask for very basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our staff members.
Suppliers
We collect some basic information on our suppliers so that things run smoothly. We process contact information for individuals within the organisations, bank details and correspondence.
Where do we collect personal data about you from?
The following are the different sources we may use to collect personal data about you:
Candidates
Directly from you, also via direct applications from job boards. This is information you provide while searching for a new opportunity and/or during the different recruitment stages.
Through publicly available sources. We use the following public sources:
- Company websites
- News articles
By Reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer.
Clients
Directly from you. This is information you provide to us when you engage us to provide a service/ask us for us to pitch our services.
Third party acting on your behalf. e.g. in-house recruitment teams or other recruitment firms.
Through publicly available sources. We use the following public sources:
- Company websites
- News articles
Networks/referrals/colleagues
Referees or Emergency Contacts
This information is taken directly from candidates or from staff.
Suppliers
We collect your personal data during the course of our work with you.
How do we use your personal data?
Candidates
Executive Search / Interim Search / Board Search
We use your personal data to assess your suitability, strengths and weaknesses for roles and fit within a company culture and environment. We will initially collect basic information on you such as contact details, job role and experience and then pass this on to the client in search of personnel. If you are chosen by the client and go through to the next stage, we will then be collecting more information from you at the interview (or equivalent) stage and onwards in that manner.
Business Development
In some instances we may use your information for business development purposes. If we believe that our services may be of interest to you in a professional capacity we may approach you with potential candidates or for developing a business relationship. If you would rather not be contacted for this purpose please let us know at gdpr@hjexecutive.com.
Clients
Business Development / Providing Services
We use your personal data to help us to provide you with our services or for us to approach you about engaging our services. We will collect information on you such as contact details and job role and other publically available information and then use this to help us maintain our relationship, help us to fulfil a contract or for business development.
Referees or Emergency Contacts
We use referees’ personal data to help verify our candidates details and qualifications. We may also use referees’ personal data to contact them in relation to recruitment activities that may be of interest to them. Emergency contact’s information is used only in the case of an accident or emergency affecting a member of staff.
Suppliers
We use the personal data of Suppliers to ensure that the arrangement between us can be properly maintained and implemented.
How long do we keep your personal data for?
We keep your information in accordance as follows:
- Permanent Candidate data: 6 years from collection
- Interim Candidate data: 3 years from collection
- Placed Permanent and Interim data: 6 years from placement or end of contract
- Potential Client data: 3 years
- Client Contact data: 6 years from end of contract
- Referee: 6 years after the end of the contract
- Emergency Contact: the duration of the contract of the Employee
- Supplier Data: 6 years after end of relationship
When determining the relevant retention periods, we will take into account factors including:
a) out contractual obligations and rights in relation to the information involved;
b) legal obligation(s) under applicable law to retain data for a certain period of time;
c) our legitimate interest where we have carried out a balancing test (see legal basis below);
d) statute of limitations under applicable law(s);
e) (potential) disputes;
f) if you have made a request to have your information deleted; and
g) guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information where we no longer require it for the purposes collected.
Who do we share your personal data with?
Candidates
We share your personal data with the client who has a position to fill, in order to determine with the client whether you are a good fit for the available position. We may also conduct reference checks on you to verify the information you have provided; where we do this your details are shared with the referee you have specified for confirmation.
We help clients in the areas of Digital and Technology, Marketing, Finance, HR, Business Programmes, Customer Experience/Operations, Procurement and Commercial Services across sectors such as Energy, Water, Transport, Construction, Engineering and Infrastructure, Consumer Retail and Professional Services within the UK and Europe.
As part of our legal requirement, if we have placed you into an interim management position we are required to inform HMRC of certain personal information (more information can be found here).
On occasion we share information with our affiliate company Calibre One Limited. We only do this if we believe that you could be a suitable candidate for a requirement Calibre One is trying to fill.
Clients
We may share your data with our affiliate company Calibre One if we believe that their services may be of some use to you or your company’s requirement needs. If you would prefer we do not share your information in this way please contact us on gdpr@hjexecutive.com.
Referees or Emergency Contacts
Where a reference has been provided, the reference together with the referee name and job title will be shared with our client. Emergency contact information will be shared with the emergency services if required.
Suppliers
We may share your details if we think that your goods/services would be of benefit
What legal basis do we have for using your information?
Candidates
Candidate processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles; to find potential candidates and to contact clients and referees. We carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests before we go ahead with such processing. We keep a record of these balancing tests. You have a right to and can find out more about the information in these balancing tests by contacting us using the details below.
If you are shortlisted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as health information that you have provided. In that case, we always ask for your consent before undertaking such processing.
Clients
Our processing is necessary for our legitimate interests in that we need the information in order to be able to develop future business, maintain business relationships and provide our services to you as a client or potential client.
We may also rely on our processing being necessary to perform a contract for you.
Referees or Emergency Contacts
Taking references is an important part of our Candidate quality assurance and is therefore processed for our legitimate interests.
Suppliers
Contacting suppliers for the purpose of an agreement or to engage you for services is important to the running of our business and we deem it necessary to process this data for our legitimate interest.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary, or withdraw yourself from the processing of your personal data, we may not be able to match you with available job opportunities.
Do we make automated decisions concerning you?
No, we do not carry out automated profiling.
Do we use cookies to collect personal data on you?
We do not collect data from users of our website.
Do we transfer your data outside the EEA?
On occasion, if we think that your profile fits with a specific client, we may transfer your personal data to these clients and partners in countries outside the EEA. These countries privacy laws may be different from those in your home country. Where we transfer data to a country which has not been deemed to provide adequate data protection standards, we always have security measures and approved model clauses in place to protect your personal data. To find out more about how we safeguard your information as related to transfers contact us on gdpr@hjexecutive.com.
At present we do not have any clients outside of Europe but should this change details will be provided here.
What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
Rights | What does this mean? |
The right to be informed
|
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy. |
The right of access | You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy).
This is so you’re aware and can check that we’re using your information in accordance with data protection law. |
The right to rectification | You are entitled to have your information corrected if it’s inaccurate or incomplete. |
The right to erasure | This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions. |
The right to restrict processing | You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future. |
The right to data portability | You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. |
The right to object to processing | You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities). |
The right to lodge a complaint | You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator. |
The right to withdraw consent | If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for business development/marketing purposes. |
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
How will we contact you?
We may contact you by phone, email or social media. If you prefer a particular contact means over another please just let us know.
How can you contact us?
If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact us here: Audrey House, 16-20 Ely Place, London, EC1N 6SN gdpr@hjexecutive.com.
Changes to the Privacy Policy
Harrison James reserves the right to modify or amend the Privacy Policy at any time and for any reason, as permitted by applicable law. If there are material changes to the Privacy Policy, we will post those changes here.