|Company Name:||Bateman Collins Group (BCG)
Incorporating Bateman Collins International Limited and Map Room Limited
|Data Protection Lead||Zoe Evans
|Privacy Notice (when personal data is obtained from the data subject and when personal data is obtained from a third party)
|Data Protection & Information Security
|V1.11 – 14 May 2018|
This Privacy Notice explains in detail the types of personal information we may collect about you when you interact with us. It also explains how we’ll store and handle that information, and keep it secure.
We hope the following sections will answer any questions you have but if not, please do get in touch with us at firstname.lastname@example.org.
In the future we may need to update this Privacy Notice. When we make any changes to the BCG Privacy Notice we will notify you of these changes.
2. What is the Bateman Collins Group?
3. Data Collection and Usage
BCG collects, holds and processes personal information (including sensitive personal information) in connection with our search, assessment, leadership advisory and other services. We may be in the process of recruiting you as a Candidate for a role with a Client, identifying exceptional Candidates for you as a Client, retaining you as a Vendor, or engaging with you as a Referee in relation to one of our Candidates.
4. Candidate Information
You may give your personal information to a BCG company directly, such as on a job application, registration form or via our website; or you may email your CV or speak to a BCG consultant directly; or we may receive your information from another publicly available source or a third party, such as LinkedIn or a career website. If the Company sourced your information from a third party we will inform you how we obtained your information and whether the information came from a publicly accessible source.
By providing your personal information to BCG you agree that you would like to be considered for confidential executive search assignments which we undertake on behalf of our Clients. You are not obligated to provide a BCG company with any information or participate in any of the services we offer. As such, we will consider any information we collect directly from you as having been provided voluntarily.
The personal information which we will typically need include information from your CV such as your name, address, phone number, email address, employment history, education and qualifications. It may also include remuneration and compensation information, contact history and reference information.
We may also collect and hold sensitive information. This may include information relating to age, nationality, race and ethnicity, religious beliefs, trade union and political party membership, sexual orientation, fraud and criminal record. We may also collect and hold demographic and diversity information to help our Clients address diversity needs. Where we need to process your sensitive information, we will obtain your specific consent and provide a clear explanation as to why we need to process this information.
Where we progress your application, we may need to gain your consent to verify accuracy of information you have provided, such as your identity, right to work, address or work history, qualifications, work performance as well as contacting Referees. We will only process information where we have a legal base to do so.
5. Client Information
We may need to collect and use information about you or individuals at your organisation whilst providing our services to you. We need to have your contact details such as name, telephone number and email address as well as maintaining an accurate record of our interactions to ensure that we manage our relationship with you smoothly and efficiently.
Where appropriate and in accordance with the law, we may seek more information about you or your colleagues from other sources, generally by way of due diligence or other market intelligence including from third party market research and by analysing publicly available sources of information such as online media.
We may also hold your information in order to provide you with reports, white papers, market insight and analysis that we think you may find interesting (in each case, where this is accordance with your preferences).
6. Reference and Source Information
In securing a reference about one of our Candidates, we may contact you for a reference and process your contact details such as name, email address and telephone number. We may also process certain professional information such as your job title, current employer and employment history. We may also process information such as your relationship to the Candidate and your experience and professional view of the Candidate’s capabilities. We generally ask the Candidates to provide us with much of this information but we may supplement it with information we collect about you from publicly available sources such as LinkedIn or through the contact with you directly.
7. Explaining The Legal Basis for processing your Personal Information
The law on information protection sets out the different reasons for which a company may collect and process your personal information. These legal bases for which we collect your personal information are listed below:
(a) Legitimate interest. In most cases BCG will process your personal information in the legitimate interest of providing you, our Clients and Candidates with Executive Search and Leadership Advisory Services. We will hold, collect and process your personal information so long as it does not infringe nor impact your rights, freedom or interests.
(b) Consent. In specific situations, we will collect and process your information with your consent. For example, there may be occasions when we need to process sensitive personal information such as on the occasion you are required to undertake a pre-employment criminal record check. On these occasions we will request your specific consent to obtain and process this information.
(c) Contractual obligations. In certain circumstances, we need your personal information to comply with our contractual obligations. For example, we may need to process your information in order to facilitate payment to our consultants, associates, interim managers or contractors.
(d) Legal compliance. Where the law requires us to, we may need to collect, process and disclose your personal information to comply with a statutory or legal requirement. For example, we may need to disclose your personal information to comply with statutory HMRC intermediary reporting.
You have the right to know what information we hold, how we are processing your information and on what legal basis. If you have any questions about the legal basis for processing your personal information, please refer to Section 13 ‘Your Rights’ or contact us directly at email@example.com.
8. How we will use your Personal Information
BCG may process your personal information in the following ways: –
(a) Collecting, storing and processing personal information for the purpose of providing you with Executive Search and Leadership Advisory services;
(b) Providing these services to Clients and Candidates which includes notifying you of senior positions or opportunities which are assigned to us;
(c) Assessing and reviewing your suitability for these Executive Search assignments and validating the information you have provided to us through referencing and vetting procedures;
(d) Introducing you to our Clients;
(e) Responding to your enquiries as a Candidate or Client;
(f) Carrying out the necessary administration when supporting your introduction to a Client in a role i.e. managing payroll;
(g) Collating market research and information analysis or sector specific information for the purposes of providing you as a Candidate or Client with reports, white papers, industry insight and analysis;
(h) In line with your marketing preferences, providing you with these reports, white papers, industry insight and analysis, news, events and other information. Where we do so, you will be able to unsubscribe from such communications;
(i) Processing equal opportunities monitoring information to meet our commitment to equal opportunities whilst collecting diversity information to help our Clients achieve their diversity objectives;
(j) Processing sensitive personal information (such as health, fraud, credit history and criminal record information) where required by law or where these are required for a position for which we are recruiting;
(k) Retaining a record of our interactions with you;
(l) Establishing quality, training and compliance with our obligations and to meet our internal standards and industry best practice.
9. Transfer of Personal Information
BCG may share your personal information with trusted third parties where we have employed them to provide services that Candidates or our Clients have requested, for example criminal reference checking services or companies who offer psychometric testing. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality as BCG.
BCG may share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as our selected IT vendors and mailing houses. These third parties will have agreed to comply with the principles of GDPR as outlined in our Data Processor Agreements.
We may also release personal information to regulatory or law enforcement agencies, if they require us to do so. We will also disclose your information where we are permitted and requested to do so by law.
In the case of Candidates and Referees we may share your information with Clients who will need to process your information for the purposes we have described in this Notice.
For Referees, we endeavour to keep your information confidential from the Candidates you discuss with us, but under limited circumstance, your information may be disclosed to them.
Your information will be shared between our BCG companies (Bateman Collins International & Map Room Consulting) so that you may be contacted in relation to the Executive Search and Leadership Advisory services that BCG provide.
If the Bateman Collins Group is acquired by another business or company, we may share personal information with the new owners of the business or company and their advisors and if this happens, we will promptly notify you of such an event.
Please be assured that we never sell your information to third parties or use the information for purposes other than those outlined in this policy.
10. Obtaining your Personal Information from a Third Party
As part of our legitimate interest we may research information relating to Candidates for the purposes of providing Executive Search and Leadership Advisory services for Clients and Candidates. This may include obtaining personal information from online sources, for example we may obtain information from social media sites such as LinkedIn and career websites. From time to time we may also receive personal information about Candidates and Clients from colleagues and former employers, or from persons for whom have been otherwise engaged.
Where information from third party sources is of no use to us, or where you have notified us that you do not want us to provide you with services, we shall delete it. Further, it is our policy that we keep a record of how your information was collected and will be happy to provide you with this information as pursuant to your individual rights (please see Section 13).
11. Information Storage and Retention
Your personal information provided to a BCG company will be held securely within our database. Our centralised database is only accessible by BCG employees and our selected and vetted IT vendors who adhere to our strict privacy and confidentiality principles.
We will retain your information where we have a legitimate business interest to provide you with our Executive Search and Leadership Advisory services or where we have a legal or contractual obligation to do so.
Please note that where there is not ongoing legitimate business interest the following sets out the lengths of time we are required by law to retain your information or certain elements of your information:
(a) for 12 months from the date we last provided our Executive Search and Leadership Advisory services to you for the purposes of providing evidence of these services we provided to you (Regulation 29 of the Conduct of Employment Agencies and Employment Businesses Regulations 2003);
(b) for 2 years from the end of your last period of engagement or employment for the purposes of providing evidence that right to work checks were carried out under The Immigration (Restrictions of Employment) Order 2007;
(c) for 3 years from the end of the relevant year for the purposes of any parental/adoption leave records or statutory maternity or paternity pay; and
(d) for 6 years from the end of each tax year for the purposes of retaining payroll records under the Income Tax (Employment and Pensions) Act 2003,
(e) for 6 years from the end of each tax year for the purposes of keeping VAT records for any VAT registered limited company contractors.
If, however you have any questions about how long we store your personal information or would like to talk to us about having your personal information deleted or anonymised please contact our Data Protection lead at firstname.lastname@example.org.
12. Data and Information Security
We take appropriate steps to ensure your information is kept secure at all times. We have technology and organisational safeguards in place to protect against the loss, destruction, misuse, disclosure and unauthorised access to personal information under our control. Unfortunately, the transmission of information via the internet cannot be guaranteed secure. Whilst we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
13. Your Rights
Please be aware that you have the following data protection rights:
(a) The right to be informed about the personal information the Company processes on you;
(b) The right of access to the personal information the Company processes on you;
(c) The right to rectification of your personal information;
(d) The right to erasure of your personal information in certain circumstances;
(e) The right to restrict processing of your personal information;
(f) The right to information portability in certain circumstances;
(g) The right to object to the processing of your personal information that was based on a public or legitimate interest;
(h) The right not to be subjected to automated decision making and profiling; and
(i) The right to withdraw consent at any time.
Please note that if you exercise your right to erase your personal information you will not be able to be included in any executive search assignment or approached for any BCG project.
Where you have consented to the Company processing your personal information you have the right to withdraw that consent at any time by contacting our Data Protection Lead at Bateman Collins on +44 203 740 9040 or at email@example.com.
If you wish to withdraw consent we will only retain minimal information to prevent future contact, or to keep a record of the information disclosed in line with our legal obligations.
14. Automated Decision-Making
If Bateman Collins Group uses your personal information in automated decision-making, including profiling, we will provide meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the individual upon request.
A cookie is a small file placed onto your device that enables website functions and targeted advertising. Cookies are very commonly used on modern websites, and their aim is to improve user experience by gathering information on how the website is performing.
Our website requires cookies to function properly. We define cookies as either:
(a) ‘first party cookies’, which are cookies set and managed by BCG and
(b) ‘third party cookies’ which are set and managed by other organisations
We use ‘first party cookies’ to offer you the best possible user experience on our website. We categorise cookies used on batemancollins.com into two categories:
(a) Analytics & Research: these cookies help us analyse how well our site is performing. We use this information to improve your experience on our website.
Bateman Collins may on occasion use ‘third party cookies’ such as Google Analytics to assist with analysing the performance of our website.
You can control the usage of cookies in your web browser settings. You can disable cookies completely if you want to, but this could mean that batemancollins.com may not function properly and cannot offer you the best possible user experience.
16. Contact Us
You also have the right to raise concerns with the Information Commissioner’s Office on +44 303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal information be processed outside of the UK, if you believe that your information protection rights have not been adhered to.
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