This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC).
The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purposes of data protection legislation in force from time to time the data controller is Capital Futures of Gridiron Building, 1 Pancras Square, King’s Cross, London, N1C 4AG Our nominated representatives can be contacted at email@example.com.
Who We Are and What We Do
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business).
We collect the personal data of the following types of people to allow us to undertake our business:
- Prospective and placed candidates for permanent or temporary roles;
- Prospective and live client contacts;
- Supplier contacts to support our services;
- Employees, consultants, temporary workers;
- Website Users;
We collect information about you to carry out our core business and ancillary activities.
Information You Give to Us or We Collect About You
This is information about you that you give us by filling in forms on our website www.cfutures.com or by corresponding with us by phone, email or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions, enter a competition, promotion or survey.
The information you give us or we collect about you may include your name, address, private and corporate email address and phone number, financial information (where we need to carry out financial background checks), employment history, emergency contacts, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website. Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health, diversity information or details of any criminal convictions.
Information We Collect About You When You Visit Our Website
With regards to each of your visits to our website we will automatically collect some or all of the following information if you are already on Capital Futures’s database, otherwise this information will only be collected when you subscribe to communications, register for an account, apply to job applications or use other website services:
Technical information, including but not limited to First Name, Last Name, email address, City, Country, Number of Pageviews, Average Pageviews, Time of First Visit, Time of Last Visit, IP Address, IP City, Country, State/Region, Website URL. If you complete the contact us form we will also collect your First Name, Last Name, Email Address and anything else you may freely disclose.
Please note that the level of information collected on visiting our website depends largely on the level of interaction you have had with our site.
Information We Obtain from Other Sources
We are working closely with third parties including business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors or payroll provider. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Purposes of the Processing and the Legal Basis for the Processing
We’ve listed below various ways in which we may use and process information held about you, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive:
- To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
- To provide you with information about other services we offer, that are similar to those that you have already purchased, been provided with or enquired about.
- The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of helping secure employment or finding other work roles that might be suitable for you. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies. The more information we have, the more bespoke we can make our service.
- Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
- We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
- We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal obligations.
- We will, in some circumstances, rely on consent for particular uses of your data and you will be asked for your express consent, if legally required.
An Example of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).
Our Legitimate Business Interests
Our legitimate interest in collecting and retaining your personal data is described below:
As a global executive search company we introduce candidates to clients for permanent employment. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses We Will Make of Your Data
- Use of our website;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
We will Use this Information
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to improve our site to ensure that content is presented in the most effective manner for you and for your computer; to allow you to participate in interactive features of our service, when you choose to do so; as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
What are cookies and how do we use them?
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
Cookies and Privacy
If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings.
For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
Disclosure of Your Information Inside and Outside of the EEA
We will share your personal information with:
Any member of our group both in the EEA and outside of the EEA.
Selected third parties including:
clients for the purpose of introducing candidates to them;
candidates for the purpose of arranging interviews and engagements;
analytics and search engine providers that assist us in the improvement and optimisation of our site.
CV and resume formatting providers.
We will disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Capital Futures or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or to protect the rights, property, or safety of Capital Futures, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
The lawful basis for the third-party processing will include:
Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
satisfaction of their contractual obligations to us as our data processor;
for the purpose of a contract in place or in contemplation;
to fulfil their legal obligations.
Where We Store and Process Your Personal Data
How We Safeguard Your Personal Data
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website from you; and any transmission is at your own risk. Once we have received your information, we are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access.
We will use a range of appropriate technical and organisational measures, strict procedures and security features to try to prevent loss, misuse, unauthorised access or a data breach.
If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately at firstname.lastname@example.org. Furthermore, any data security breach should be reported to us so that action can be taken to protect affected individuals and to ensure that lessons are learned to minimise the risk of recurrence.
Retention of Your Data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.
We will delete your personal data from our systems if it is likely your data will no longer be relevant for the purposes for which it was collected.
The criteria we use to determine whether we should retain your personal data includes:
the nature of the personal data;
its perceived accuracy;
our legal obligations; and
our recruitment expertise and knowledge of the industry by country, sector and job role.
We may archive part or all of your personal data, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
You have the right to ask us not to process your personal data for marketing purposes. We do not sell or disclose your personal data to third parties outside our group and we will only disclose your personal data if we are legally required to do so
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right to remove consent at any time by contacting us at email@example.com.
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights:
Right to be informed, the right to be provided with a minimum set of information concerning the purposes for which the personal data we hold about you will be processed. As explained in this policy.
Right to access the personal information that we hold about you. This enables you to have access/visibility to your data.
Right to rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Right to erasure (the “right to be forgotten”) of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Right to object to processing of your personal information 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 ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Right to restrict processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Right to data portability of your personal information to another party in certain formats, if practicable.
Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Access to Information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force).
A subject access request should be submitted to firstname.lastname@example.org.