Our clients might desire secrecy for a number of reasons. They might be replacing an existing team member, they perhaps recognise there is no benefit in the competition knowing they are hiring or they might be nervous about sharing sensitive commercial information with anyone – including a Headhunter.
The vast majority of the Search Assignments we conduct are carried out on a confidential basis. Only after a critical threshold has been reached will the candidate be made aware of who the client is. With regard to sensitive commercial information (e.g Annual Recurring Revenues, customer names and what they are worth to you, Average Spend etc) please don’t worry we can assure you we hear delicate information on a daily basis and it is always handled appropriately.
As a potential candidate, understandably you might be nervous about this activity becoming public knowledge. We are happy to give you a cast iron guarantee that we will never share any of your details with anyone without your express permission. This obviously includes your CV and information contained in it but it also includes information you share with us verbally.
Because of the highly targeted way in which we work it is actually very easy to give you this guarantee. Why other people who claim to be Headhunters are not this explicit is something worth considering.
Since Pathfinder was established in 2004 we have never had an issue with privacy or confidentiality. We have never put anyone’s existing role in jeopardy and we have never shared private or sensitive information that we were not suppose to. We take this very seriously and believe that it really is the absolute minimum our clients and candidates should expect from us or any other Headhunter.
Pathfinder Executive Search & GDPR
In light of the GDPR regulations coming into effect we have decided to create a more comprehensive policy but in reality precise highly targeted nature of out business meant we were already compliant in almost every way.
Welcome to the updated Pathfinder Executive Search privacy notice.
Pathfinder Executive Search respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and when you engage with us as a client for our services and tell you about your privacy rights and how the law protects you.
This privacy notice includes the sections outlined below. Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Pathfinder Executive Search collects and processes your personal data through your use of our website and our services.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
Pathfinder Executive Search Ltd is the controller and responsible for your personal data (collectively referred to as “Pathfinder”, “we”, “us” or “our” in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full details are:
Full name of legal entity: Pathfinder Executive Search Ltd
Name or title of DPO: Bruce Wright, Founder and MD
Email address: Bruce@Pathfinderes.co.uk
Telephone number: 0203 66 73 8 73
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 24th May 2018 and historic versions can be obtained by contacting us.
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.
Our 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 notice of every website you visit.
- The data we collect about you
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 (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Career Data includes job title and company name
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your tenure in your current position to calculate the mean average people hold a certain type position for. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel the service we are providing to you but we will notify you if this is the case at the time.
- How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or
by corresponding with us by post, phone, email or otherwise. This includes personal data you provide
o make an enquiry as to our services;
o subscribe to our service;
o request marketing to be sent to you;
o give us some feedback.
- Third parties or publicly available sources.
We may receive personal data about you from various
third parties and public sources as set out below:
- Technical Data from analytics providers such as Google based outside the EU.
- Identity and Contact Data from publicly availably sources such as Linkedin and Companies House.
- How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
To find out more about the types of lawful basis that we will rely on to process your personal data please review the table below.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan 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.
We do not use your data to send you direct marketing. We will get your express opt-in consent before we share your personal data with any company outside Pathfinder for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of us providing services to you or other transactions.
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.
- Disclosures of your personal data
We will not and have never shared personal information with any 3rd party without the express permission of the individual concerned. For example sharing a CV or career details with a potential employer has only ever done been done with consent. This applies even when that 3rd party may exist outside of the reach of GDPR in another country.
- 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, 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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.
- Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- 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.
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.
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.
Consent means that the individual or business has given clear consent for us to process their personal data for a specific purpose.
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.
External Third Parties
- Service providers acting as processors based in the UK who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, accountants, bankers, independent financial advisors, auditors and insurers based in the UK who provide consultancy, banking, financial, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers
based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.