Accreto Solutions, and our affiliates (“we” “us” “our”) are a specialist advisory firm that provides a top tier resourcing, research and advisory service on a global basis.
Accreto Solutions is committed to keeping your information secure and managing it in accordance with our legal responsibilities under privacy and data protection laws, where applicable.
2. CONTACT DETAILS
Our full details are:
Accreto Solutions, Adrian de Vere Green, Data Privacy Manager Email address: firstname.lastname@example.org Postal address: 7 Bell Yard, London, WC2A 2JR, United Kingdom
This version was last updated on 30 April 2019. 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.
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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 –
This includes first name, last name, marital status, family, employment history, education, biography, character reference, date of birth and gender.
Contact Data –
This includes email address, telephone, postcode and address.
Preference Data –
This includes preferences, interests and feedback.
Sensitive Data –
which includes but is 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 to 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
- Publicly available sources, such as company corporate websites
- Regulatory Filings
- 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 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.
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 grounds we are relying on to process your personal data.
|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 (prospective candidates)
c) To provide corporate clients with Consulting Services
|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) Performance of a contract/services with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our recordsaccurate 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)
|(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.
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 fulfil 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
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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.
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.
External Third Parties means:
Our corporate clients who have registered and instructed us in relation to Recruitment Services and/or Consulting Services, based in the UK and the ROW.
Service providers acting as processors based in the UK who provide IT and system administration services.
Professional advisors acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and the USA, who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the UK 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 processing it lawfully.
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 overrides 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.
Right to make a complaint. 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.