Privacy policy

This Privacy Policy sets out the basis on which Metropole Associates Limited (Company Number 06688157) trading as Fraser Giles Partnership, will process personal information provided to us (personal data).

We take our obligations in respect of the privacy of personal information very seriously and we will only process personal information as detailed in this policy unless we inform you otherwise. In order to ensure that the personal information we hold is accurate and up-to-date, we request that you inform us of any relevant changes to the personal information we hold about you.

For the purposes of this Privacy Policy, our commercial activities and services for individuals and businesses are referred to as ‘Executive Search’ and our actual or potential hiring customers are referred to as ‘Clients’.

The person responsible for data protection within our organisation is Eleanor Doe: privacy@fgpartnership.com.

If you do not wish us to process personal information in accordance with this policy, then please do not provide it to us. Please refer to Section 4 ‘Your rights’, in respect of data that we already hold, or which we receive from third parties.

SECTION 1: THIS SECTION APPLIES TO INDIVIDUALS USING OUR EXECUTIVE SEARCH SERVICES (‘A CANDIDATE’)

The personal data we collect or receive includes the following as applicable:

  • Name
  • Address
  • Email and other contact details
  • Date of birth
  • Job history (including information relating to placements through us)
  • Educational history,  qualifications & skills
  • National insurance and tax (payroll) information (for staff only)
  • Contact details of referees
  • Personal information relating to hobbies, interests and pastimes
  • Information contained in references and pre-employment checks from third parties

We may obtain your personal data from the following sources (please note that this list is not exhaustive):

  • You (e.g. a Curriculum Vitae, application or registration form)
  • A Client
  • Other candidates
  • The public domain
  • Social media
  • At interview
  • Conversations on the telephone
  • Notes following a conversation or meeting
  • Our websites and software applications

Where you are a Candidate and we have obtained your personal data from a third party, it is our policy to advise you of the source when we first communicate with you.

How we will use your personal data:

The processing of your personal information may include:

  • Collecting and storing your personal data, whether in manual or electronic file
  • Notifying you of potential roles or opportunities
  • Assessing and reviewing  your suitability for job roles
  • Introducing and/or supplying you to actual or potential Clients
  • Engaging you for a role with us or with our Clients
  • Collating market or sector specific information and providing the same to our Clients
  • Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers
  • Retaining a record of our dealings
  • Establishing quality, training and compliance with our obligations and best practice
  • For the purposes of backing up information on our computer systems

Why we process your personal data:

1. Entering into a contract with you:

In order to provide our Executive Search Services we may enter into a contract with you and/or a third party. In order to enter into a contract we will need certain information, for example your name and address. A contract will also contain obligations on both your part and our part and we shall process your data as is necessary for the purpose of those obligations.

2. Compliance with legal obligations (regulatory and statutory obligations):

We must comply with a number of statutory provisions when providing our Executive Search Services, which necessitate the processing of personal data.

We are also required to comply with statutory and regulatory obligations relating to business generally, for example complying with tax, bribery, fraud/crime prevention and data protection legislation, and co-operating with regulatory authorities such as HMRC or the Information Commissioner’s Office.

3. Our legitimate interests (carrying on the commercial activity of Executive Search Services):

In providing our Executive Search Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include:

  • Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
    – establishing compliance with contractual obligations with Clients or suppliers
    – addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
    – protecting our reputation
    – maintaining a back-up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
    – evaluating quality and compliance including compliance with this Privacy Notice
    – determining staff training and system requirements
  • Using your personal data to:
    – assess suitability and contact you regarding potential opportunities and/or our service
    – collate market information or trends including providing analysis to potential or actual Clients
    – source potential opportunities or roles as part of our Executive Search Services

This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes.

4. Consent to our processing of your data:

We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you apply for a specific role you may have consented to our processing of the data that has been provided for the purpose of progressing your application and considering your suitability for that role. In other cases you may have provided your written or verbal consent to the use of your data for a specific reason.

You may withdraw your consent to our processing of your personal information for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.

What if we obtain your personal data from a third party?

Part of our business activity involves researching information relating to individuals for the purposes of filling job roles. This may include obtaining personal data from online sources, for example we may obtain information from social media sites such as LinkedIn and job boards, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal information about you from hiring organisations, colleagues and former employers, or from persons for whom you have provided services or 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 discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Executive Search Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see Section 4 ‘Your rights’.

Sensitive Personal Data (SPD)

Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our consideration of your suitability for a job role. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.

Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that data for the purposes of our relationship with you or for the provision of our Executive Search Services. This will be for one or more of the following reasons:

  • You have explicitly consented to the processing
  • For the purpose of our assessment of your suitability for job roles or working capacity
  • Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law
  • To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims

Who we share personal data with:

We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information include:

Individuals, hirers and other third parties necessary for the provision of our Executive Search Services

  • Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
  • Legal and professional advisers
  • Insurers

Automated decisions

We do not use any automated decision making software.

 

SECTION 2:
THIS SECTION APPLIES WHERE YOU ARE AN INDIVIDUAL WORKING FOR A THIRD PARTY WITH WHOM WE HAVE DEALINGS. FOR EXAMPLE, A CLIENT

We may collect your personal data in the course of our dealings and this may include the following:

  • Your contact information, which may include your full name, job role, contact telephone number and email
  • Your statements and opinions about candidates and/or other personnel e.g. a reference
  • Information relating to our relationship with you or the party for whom you work including records of any meetings or discussions
  • Your marketing preferences

We may obtain your personal data from the following sources:

  • You, including where you have provided us with your contact details or other information for the purposes of using our Executive Search Services
  • Staff or other representatives of the organisation you represent
  • Candidates
  • Marketing databases
  • Social media
  • The public domain
  • Conversations, with you or others, on the telephone or in meetings
  • Notes following a conversation, with you or others, or meetings you attend

How we will use your personal data:

We will process your personal data in the context of our dealings with the third party for whom you work and as part of our Executive Search Services. Processing may include:

  • Collecting and storing your personal data, whether in manual or electronic files
  • Using the data to communicate with you
  • Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Executive Search Services
  • Actions necessary to further any obligation on us pursuant to a contract between ourselves and the third party you work for
  • Collating market or sector specific information and providing the same to our clients
  • Providing information to regulatory authorities or statutory bodies and our legal or other professional advisers including insurers
  • Retaining records of our dealings with you and the organisation whom you represent
  • Establishing quality, training and compliance with our obligations and best practice

Why we process your personal data:

1. Compliance with legal obligations (regulatory and statutory obligations):

We must comply with a number of statutory provisions when providing our Executive Search Services, which necessitate the processing of personal data.

We are also required to comply with statutory and regulatory obligations relating to business generally, for example tax, bribery and fraud/crime prevention legislation, and co-operating with regulatory authorities such as HMRC.

2. Our legitimate interests (carrying on the commercial activity of Executive Search Services):

In providing our Executive Search Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include:

  • Using your personal data:
    – to contact you regarding our Executive Search  Services
    – to assess suitability of Candidates and roles, for example, referencing or other feedback
    – to collate market information or trends including providing analysis to potential or actual Clients
    – as otherwise necessary to provide our Executive Search Services and/or to meet our obligations towards either the party whom you represent, or other Clients or suppliers
  •  Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
    – establishing compliance with contractual obligations with Clients or suppliers
    – addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
    – protecting our reputation
    – maintaining a back-up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
    – evaluating quality and compliance including compliance with this Privacy Notice
    – determining staff training and system requirements

For our commercial viability and to pursue these legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate for these purposes.

3. Consent:

We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you have provided your contact details in order that we may use these to provide you with details of our services you may have consented to our processing of the data for that purpose. In other cases you may have provided your written or verbal consent to the use of your data for a specific reason, for example references.

You may withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.

What if we obtain your personal data from a third party?

Part of our business activity involves researching information for the purposes of finding and filling job roles. This may include obtaining personal data from sources including job boards, advertisements, LinkedIn or other social media, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal data about you from clients, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged.

Where information from third party sources is of no use to us we shall discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Executive Search Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see Section 4 ‘Your rights’.

Sensitive Personal Data (SPD)

Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our dealings with you in respect of our Executive Search Services. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.

Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that personal data for the purposes of our relationship with you or for the provision of our Executive Search Services. This will be for one or more of the following reasons:

  • You have explicitly consented to the processing
  • Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law
  • To maintain records of our dealings to address any later dispute, including but not limited  to the establishment, exercise or defence of any legal claims

Who we share personal data with:

We shall not share your personal data unless we are entitled to do so. The categories of persons with whom we may share your personal information include:

  • Candidates and other third parties necessary for the provision of our Executive Search Services
  • Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
  • Legal and professional advisers
  • Insurers

 

SECTION 3:
THIS SECTION APPLIES TO ALL PERSONAL DATA

Transfer

In the event  of a sale, merger, liquidation, receivership or the transfer of all or part of our assets to a third party, we may need to transfer your information to a third party. Any transfer will be subject to the agreement of the third party to this Privacy Notice and any processing being only in accordance with this Privacy Notice.

Data Security and Confidentiality

It is our policy to ensure, in so far as is reasonably practicable, that we have in place appropriate technical and organisational measures and that our systems and records are secure and not accessible to unauthorised third parties in line with contemporary practice.

Cookies

A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website, which enables the website to tailor its offerings to your preferences when you visit it.
We use cookies on our website.

Retaining your data

It is our policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests.

If however you believe that we should delete your personal data, please inform us in writing of your reasons.  Please see Section 4 ‘Your Rights’ below.

Changes to this Privacy Notice

This Privacy Notice is regularly reviewed and may be updated from time to time to reflect changes in our business, or legal or commercial practice.

 

SECTION 4:
YOUR RIGHTS

We take the protection of your personal data very seriously and it is important that you know your rights within that context, which include rights to:

  • Request a copy of the personal data that we hold
  • Object to our processing of your data where that processing is based upon legitimate interest and there are no compelling grounds for the continued processing of that data
  • Request that we restrict processing of your data in certain circumstances
  • Request that data is erased where the continued use of that data cannot be justified
  • Object to any decision, which significantly affects you, being taken solely by a computer or via another automated process
  • Withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations
  • Request that inaccurate or incomplete data is rectified
  • Request that data provided directly by you and processed by automated means is transferred to you or another controller; this right only being applicable where our processing of your data is based either on your consent or in performance of a contract
  • Make a complaint to the Information Commissioner’s Office Request that direct marketing by us to you is stopped

Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken in order to both evidence our compliance, and to take steps to minimise the prospect of any data being processed in the future should it be received again from a third party source.

If you have any questions concerning your rights or should you wish to exercise any of these rights please contact Privacy Officer, Eleanor Doe (privacy@fgpartnership.com).

 

Complaints

If you are dissatisfied about any aspect of the way in which your data is processed you may, in the first instance refer the matter to Eleanor Doe (privacy@fgpartnership.com). This does not affect your right to make a complaint to the Information Commissioner’s Office.

 

18th July 2018