Privacy Policy
1. Introduction
Principal Search Partners Limited, and our affiliates (“we” “us” “our”) are a specialist Executive Search firm that provides a top tier resourcing, research and advisory service on a global basis (Recruiting Services). Principal Search Partners is committed to keeping your information secure and managing it in accordance with our legal responsibilities under privacy and data protection laws where applicable. This privacy policy sets out how we collect, process and look after your personal data including when you visit our website (regardless of where you visit it from) and tells you about your privacy rights. Please refer in particular to the Glossary to understand the meaning of some of the terms used.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them including but not limited to our Terms of Business.
2. Contact Details
Principal Search Partners Limited is the data controller and responsible for your personal data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Principal Search Partners Limited
Tracy White, Data Privacy Manager
Email address: tracy.white@principalsearch.com
Postal address: 7 Henrietta Street, London, WC2E 8PS
Changes to the privacy policy and your duty to inform us of changes:
This version was last updated on 22nd May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Website Third-party links:
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
3. What data we collect about you in connection with our services or via our website
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.
We may collect, use, store and transfer the following different kinds of personal data when you interact with us or via our website:
Individual Data – which includes first name, last name, marital status, family, employment history, education, biography, character reference, date of birth and gender.
Contact Data – which includes email address, telephone, postcode and address.
Preference Data – which includes preferences, interests and feedback.
Sensitive Data – which includes but not limited to race, ethnic origin, religion, biometrics (where used for ID purposes), work visa eligibility, health and sexual orientation.
4. How is your data collected?
Individual, Contact, Preference and Sensitive Data you provide us by filling in forms, or by corresponding with us by post, phone, email, by reference or otherwise pursuant to engaging in employment services with us.
We may receive personal data about you from various third parties as set out below but not limited to:
a. Linked-In
b. Publicly available sources, such as company corporate websites
c. Regulatory Filings,
d. News Alerts/Articles.
5. How we use your data
We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:
- In order to perform our contracted services we will process your personal data.
- Where we need to perform the contract
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to any Special Categories of Sensitive Data. By engaging us to provide you with Recruitment Services you expressly consent to our processing of such personal data. You have the right to withdraw consent in relation to Special Categories of Sensitive Data by contacting us, however where we need to collect such personal data by law or in order to provide the Recruitment Services, we may not be able to perform the services. In this case, we will notify you at the time
Purposes for which we will use your personal data:
We have set out below, in a table format, a description of the ways we intend to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| a) To register you as a new client b) To provide you with Recruitment Services c) To provide corporate clients with Consulting Services | Individual Contact Preference Sensitive | a) Performance of a contract with you b) Consent, where applicable, in relation to Special Categories of Sensitive Data We hold and process data for the purpose of executive and board level search. Personal data is collected, processed and distributed with the intent of identifying and presenting suitable roles for executive and board level search. c) Performance of a contract with you |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy | Individual Contact Preference | a) Performance of a contract/services with you b) Necessary to comply with a legal obligation c) (c) Necessary for our legitimate interests (to keep our records accurate and up to date |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Individual Contact Preference | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
Change of purpose:
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Disclosures of your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 5 above.
External Third Parties as set out in the Glossary.
Third parties to whom we may transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International Transfers
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. Data Security
We have put in place 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, our clients (who are External Third Parties) 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data Retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and for archiving purposes.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data; see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
10. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are further described below and in the Glossary section.
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
Right to make a complaint
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required:
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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you:
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond:
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. Glossary
LAWFUL BASIS:
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES:
External Third Parties means
Our corporate clients who have registered and instructed us in relation to Recruitment Services and or Consulting Services based in UK and ROW.
Service providers acting as processors based in UK who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK and USA who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances .
