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), the Data Protection Act [1998 OR 2018] 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
New Town Partnership Limited (“New Town”) is an executive search firm. We are registered in Scotland as a Company under SC512701 and our registered office is at 11 Alva Street, Edinburgh, Scotland, EH2 4PH.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
Our appointed Data Protection Officer and Data Controller is Louise Gibson (firstname.lastname@example.org) who is ultimately responsible for assisting with enquiries in relation to this privacy notice and our treatment of your personal data. See paragraph 10 for full contact information.
3) HOW WE MAY COLLECT YOUR PERSONAL DATA
Categories of personally identifiable data include:
- Your personal details (such as your name and/or address);
- Career history;
- Education history;
- Professional experience;
- CV and contact information;
- Details of contact we have had with you in relation to discussing recruitment opportunities;
- Our correspondence and communications with you;
- Information about any complaints or enquiries you make to us;
- Information we receive from other sources, such as publicly available information, and/or information provided by your employer or our clients.
By submitting your information to New Town Partnership, by whatever means, you indicate your willingness to disclose this information to New Town Partnership and to be considered, when appropriate, for one of New Town Partnership’s confidential executive searches. If you do not wish to disclose your personal information, New Town Partnership will be unable to provide you with our services.
We may use Personal Information to respond to your inquiries and answer your questions, to provide you with requested information, and to undertake activities in connection with the conduct and management of our executive search or other services, such as evaluating candidate qualifications, contacting potential candidates for further Personal Information, contacting named references, and communicating with Clients about potential candidates.
We also may use Personal Information for the purposes of testing and maintaining our company databases, networks, and computer systems, and for training and other internal purposes
It is not New Town Partnership’s policy to seek any sensitive information unless legally required for recruitment purposes.
Sensitive information includes data relating to:
- Race or ethnic origin
- Political opinions
- Religious or similar beliefs
- Trade union membership
- Physical or mental health
- Sexual life
- Criminal record
How We Use and Disclose Personally Identifying Information
New Town Partnership processes and disseminates Personal Data only for its own use, only for legitimate purposes, and in accordance with applicable law. Such purposes include: Executive, Board, and Management Search.
New Town Partnership processes and disseminates Personal Data in order to match Candidates who are qualified for a particular position with client organisations who have an opening for such a position.
Examples of processing for this purpose include but are not limited to:
- Collecting data from the Candidate directly;
- Performing background searches with the Candidate’s consent;
- Relaying Personal Data to a client with the Candidate’s consent;
- Receiving referrals from individuals associated with the Candidate.
By choosing to provide New Town Partnership with your personal information you indicate your willingness to share and have your information stored by New Town Partnership and to be considered, when appropriate, for one of New Town Partnership’s confidential executive searches. If you object to your information being shared and transferred in such manner or if you do not wish to participate in this service and benefit from the executive career searches that New Town Partnership provides, please request to be removed from our database by emailing: email@example.com
Your personal information may also be used anonymously and in the aggregate in order to put together industry, marketing and employment statistics. Used in this matter, your personal information becomes non-identifying.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
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.
4) 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 or where we have another legitimate interest in doing so.
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, professional advisory services and administration 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.
We may also need to share your personal data with a regulator or to otherwise comply with the law.
5) TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
We will not transfer the personal data we collect about you outside of the EEA.
6) 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, agents, contractors and other third parties who have a business need to know. 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 regulator of a suspected breach where we are legally required to do so.
7) 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: 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.
8) RIGHT TO WITHDRAW CONSENT
You have the right to withdraw your consent for your personal data to be held by New Town Partnership at any time. To withdraw your consent, please email: 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.
This privacy notice was last updated on 20th May 2018.
10) ACCESS TO INFORMATION
If you have any questions regarding this policy or if you would like to speak to us about the manner in which we process your personal data, please email firstname.lastname@example.org or telephone on 0131 210 0020.
You may also contact us in writing by addressing your correspondence to:
Data Officer, New Town Partnership, 11 Alva Street, Edinburgh, EH2 4PH.
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.
The ICO’s contact details are as follows:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns