Introduction

This website is owned and operated by Candidate Is Key Ltd. For the purposes of the Data Protection Act 1998 and the General Data Protection Regulations (GDPR) the data controller is Candidate Is Key Ltd.  In this document, "we" or "us" refers to Candidate Is Key Ltd.

 

This privacy policy outlines:

• The details of the Data Controller and how to contact the Data Protection Officer (DPO)

• The types of personal data we collect and how we use it

• Our purpose and legal basis for processing your data

• How and when we share data with Candidate is Key suppliers and partners

• How and when we use your data for marketing purposes

• Our use of cookies and your preferences with use of cookies

• Your rights to request your personal data and how to do so

• How you can raise a complaint with the ICO

 

Our policy is both specific and strict. It complies with UK law and as a data controller, is bound by the requirements of the General Data Protection Regulations (GDPR).

 

Who controls my personal data?

The Data Controller is Candidate Is Key Ltd

• Candidate is Key is a UK registered company 04267680

• The registered address is 85 Great Portland Street, London, W1W 7LT

• The Data Controller’s representative is the Data Protection Officer (DPO)

• You can contact the DPO by email michael.watson@candidateiskey.co.uk

• Candidate is Key Ltd is registered as a Data Controller with the Information Commissioner’s Office. Certificate number ZA534786

 

Our purpose and legal basis for processing your data

We provide executive search, recruitment, career coaching and outplacement services to individuals, corporate clients and ancillary services.

 

• We collect the personal data of the following types of people:

• Candidates and prospective candidates for executive search, recruitment campaigns, career coaching, career workshops, outplacement and on-line career services;

• Individual contacts of our corporate clients and our suppliers;

• Our employees, career coaches, licensees and franchisees and business connections.

 

What data will you give to us or will we collect from you?

• You provide us with your personal data by filling in forms on www.candidateiskey.com, by corresponding with us by phone, e-mail or otherwise, by subscribing to our services, sharing your details at meetings with us, attending our events, participating in discussion boards or other social media functions on our website or online, by entering a competition, promotion, or survey or by reporting a problem with our site or by voluntarily providing your personal information directly to Candidate is Key at any other time e.g. giving us your business card

• The types of personal data we collect may vary according to its purpose, we typically collect information such as: your full name, telephone number, email address, postal address, Curriculum Vitae, an application form to be submitted or an application previously submitted. We will also record any other relevant professional or personal information which is relevant to your career situation and how we might help you e.g. salary details

• Personal Data may also include links to professional sites such as LinkedIn, Twitter, or a corporate website

• We will also produce summary notes from our executive search and recruitment campaigns which will be used only for the purpose of the campaign you have submitted an application form for - or to be used in conjunction with any candidate development activities to help with career coaching and career progression.

 

What Information do we obtain from other sources?

• We may obtain information about you from other sources such as our franchisees, our licensees and suppliers, your employer, your business card, personal recommendations, or our partners

• We will let you know we are holding your data by sending you this privacy policy within a maximum of 30 days of collection

 

What are the purposes and legal bases for our processing?

We use information held about you in the following ways:

• To carry out our obligations arising from any contracts we intend to enter or have entered 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 goods and services we offer that are like those that you have already purchased, been provided with, or enquired about

• Our main 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 an 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 obligation, for example, our statutory obligation as an employer

• We will in some circumstances rely on consent for uses of your data and you will be asked for your express consent e.g. before sharing your details with a recruiter or as part of a media request

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Our Legitimate Business Interests

• To provide executive search and selection and other recruitment services, as well as career coaching, career workshops, outplacement and online career services to individuals and corporate clients

• To manage employee and contractor relationships

• To manage our corporate rights and obligations

 

Consent

• Should we want or need to rely on consent to lawfully process your data we will request your consent, 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 processing at any time

 

Other uses we will make of your data:

• To notify you about changes to our services;

• To ensure that content from our site is presented in the most effective manner for you and for your computer

• To administer our site and for internal operations, including troubleshooting, security, data analysis, testing, research, statistical and survey purposes

• To allow you to participate in interactive features of our service, when you choose to do so

• To measure or understand the effectiveness of our advertising that we serve to you and others, and to deliver relevant advertising to you

• We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process

 

Who will have access to your data inside and outside of European Economic Area (EEA)?

We will share your personal information with selected third parties including:

• Our data processors, licencees, franchisees, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter with them or you

• We will not disclose your personal information to third parties except if we sell or buy any business or assets, in which case we may disclose some of your personal data to the prospective seller or buyer of such business or assets for due diligence or substantially all our assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets

 

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 contractual obligations to us

• To fulfil their legal obligations

 

Will your data be used for marketing?

• We will only send you information about our products and services that are relevant to you

• We may send the communication in several ways including email, telephone, and post

• When you register your details with us we will ask your preferences on receiving marketing communications, you also have the right to change your preferences at any time by phone or email

 

What are cookies and how do they affect your personal data?

• Our cookies track site visitor’s basic information to better tailor the site to our visitor’s needs and improve their customer experience

• Most web browsers automatically accept cookies; however, you can disable cookies in your web browser if you wish. Please be aware disabling cookies will affect the functionality of our website and you may disable other features on the website. We recommend you do not disable cookies, in case they are used to provide a service that you use

• For more information about the cookies we use, please request a copy of our cookie policy

 

Where will we store and process your personal data?

• All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone

• The data that we collect from you may be digitally transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may be transferred to third parties outside of the EEA for the purposes of our services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and UK and EU data protection law, including contractual clauses

• 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 site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access

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How long will we retain your data?

• We understand our legal duty to retain accurate data that you are happy for us to retain and only retain personal data for as long as we need it for our legitimate business interests or to satisfy legal, accounting or reporting requirements. Accordingly, we have a data retention policy and run regular data routines to remove data that we no longer have a legitimate business interest in maintaining

 

We do the following to try to ensure our data is accurate:

• We keep in touch with you, so you can let us know of changes to your personal data

• We may archive part or all your personal data or retain it on our financial systems. 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

• Our current retention policy is available upon request

 

Changes to this Privacy Policy

• Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy

 

How safe is your data?

• Appropriate technical and organisational measures are taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data

• We use electronic safeguards including firewalls, anti-virus and anti-malware software to protect your data

• Only authorised staff have access to personal data and are appropriately trained and supported by policies and procedures for handling personal data

• For payments, we do not retain your full card details and always require you to provide the last three digits of the security code to process a payment

• We do not recommend or guarantee the safety of your payment details sent to us electronically via email

 

What are your rights to your personal data?

• You have the right to request copies of any personal data held by us

• To receive a copy of your personal data please send your written request to the Data Controller, Candidate is Key, 85 Great Portland Street, London, W1W 7LT

• We will provide you with a hard copy of your personal data held

• You will not be charged for your personal data request

• Your data will be returned within 40 days of receiving the request

• We will require proof of identity

• You also have the right to the following:

  • The right to prevent data being processed for direct marketing

  • The right to have inaccurate personal data rectified, erased, or destroyed

  • You have the right to 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/

 

How you can access or correct your information

You can access all your personally identifiable information that we collect online and maintain by sending us an email to help@candidateiskey.com. We use this procedure to better safeguard your information.

 

You can correct factual errors in your personally identifiable information by sending us a request that credibly shows an error.  To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections.

 

You may request deletion of your personal information by us. We may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud prevention or similar purposes.

 

Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

 

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

 

Third party advertising

Third parties may advertise on our web site. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects your IP address when they send an advertisement that appears on our site to your browser. They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts. We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

 

Information we obtain from third parties.

Although we do not disclose your personal information to any third party (except as set out in this notice), we do receive data which is indirectly made up from your personal information, from software services such as Google Analytics and others. No such information is identifiable to you.

 

Affiliate information

This is information given to us by you in your capacity as an affiliate (or reseller) of us or a customer or client of ours. Such information is retained for business use only. We undertake to preserve the confidentiality of the information and of the terms of our relationship. It is not used for any other purpose. We expect any affiliate to agree to reciprocate this policy. As an exception to this, we have the right to disclose your first name and URL of your affiliate connection to other affiliates and to any other person or organisation, on and off site. The reason is solely to enable us to mention winners and others whose performance as an affiliate is in some way outstanding.

 

Disclosure to Government and their agencies

We are subject to the law like everyone else. We may be required to give information to legal authorities if they so request or if they have the proper authorisation.

Data may be "processed" outside the UK.

Our web sites are hosted in the EU. We also use outsourced services in countries outside the EU from time to time in other aspects of our business. Accordingly, data obtained within the UK may be "processed" outside the UK and data obtained in any other country may be processed within or outside that country.

 

Complaining

When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and, if we do, what that information is.

 

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

 

Compliance with the law

This privacy policy has been compiled so as to comply with the law of every jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your country, we should like to hear from you, but ultimately it is your choice as to whether you wish to use our website.  If you think our policy falls short of your expectations or that we are failing to abide by our policy, do please tell us.

 

We regret that if there are one or more points above with which you are not happy, your only recourse is to leave our web site immediately. Except as set out above, we do not share, or sell, or disclose to a third party, any personally identifiable information collected on our websites.

 

Last Updated: 07/10/2022

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