Blackwood, 6 Gracechurch Street, London EC3V 0AT, is a human capital advisory firm focused on helping our clients address their most fundamental business needs – advising on leadership; and talent identification, assessment, recruitment and retention. As a data controller, we are committed to protecting the privacy of your personal data and we summarize here our policies regarding the collection, use and transfer of your personal data, the security measures we employ to protect such data and your rights and choices with regard to access or use of such data.
We collect a variety of personal data in order to provide our advisory services. For candidates, this typically includes employment history, degree(s) and other qualifications, languages and other skills as well as contact information. It may also include, age, nationality and gender, compensation details (where permitted by applicable legislation), a record of our contact history with you and comments, views or references from third parties. Where applicable, it will also include interview notes and a record of individual preferences and competencies. We advise you not to provide information which may be deemed sensitive on your CV as we will retain any documents that you have provided. For clients and potential clients, referees and sources data typically includes contact details, company information and role and for anyone receiving assessment or coaching from us, we will also process any additional personal data that you choose to provide to us during the course of either of these. In addition to information provided by you, we may gather information from LinkedIn, Google, Company websites, press and periodicals and other publicly available sources as well as third parties such as sources/referees. Selectively, we may hold sensitive personal data if relevant to a specific search and subject to your explicit consent.
Legal Basis for Using Your Data
For prospective candidates, candidates, referees, sources and clients, our processing is necessary for our legitimate interests in that we require the information in order to be able to assess suitability for potential opportunities, to find potential candidates and to contact clients and referees. We carry out a “balancing test” to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we proceed with the processing. We keep a record of these balancing tests. You can find out more about the information in these balancing tests by contacting us using the details below.
If you are coached or assessed by us, then this may involve processing of more detailed personal data including sensitive data that you or others have provided. In these cases, we will always ask for your consent before undertaking such processing.
For clients, we may also rely on our processing being necessary to perform a contract for you.
Use and Processing of Personal Data
Data collected or received on potential candidates is used in the usual course of our business for one of Blackwood’s confidential executive or non-executive searches. Summary biographical data may be shared with a client in the context of a particular search, for example to identify the most highly qualified and talented individuals within the markets we serve or to illustrate a typical profile within the individual search parameters. No representation is made about your interest or availability to contemplate such a role at this stage. Before presenting further details or indicating any potential interest you might have, we would make direct contact with you.
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 use your data to provide the services to your organisation, to manage our relationship and account with you and your organisation.
Referees and Sources
We use your data to obtain your opinion regarding candidates in the course of providing the services to our clients. In securing a reference from you about one of our candidates, we may process your contact details. We may also process certain professional details (such as your job title and employment history) and your connection to the candidate.
Who We Share Your Personal Data With
We may share your personal data with the following types of third parties for the purposes described in this policy:
- In the case of candidates, referees, and sources, we may share your information with clients who will need to process your information for the purposes we have described in this policy.
- In the case of candidates, we may share your information with third parties who we have retained to provide services such as degree and/or license verification checks, to the extent that these checks are appropriate and in accordance local laws.
- Similarly, for candidates we may share your information with sources and referees with whom we liaise in connection with providing the services to our clients.
- For sources and referees, we endeavour to keep your information confidential from the candidates you discuss with us, but under limited circumstances, your information may be disclosed to them.
- We may share your information with any competent law enforcement body, regulatory or government agency, court or other third party where we believe disclosure is necessary as a matter of applicable law or regulation; to exercise, establish, or defend our legal rights; or to protect your vital interests or those of any other person.
- We may share your information with third party service providers (our vendors) who perform functions on our behalf (including external consultants, business associates and professional advisers, such as lawyers, auditors, accountants, technical support providers, and third party travel agencies, outsourced IT and document storage providers).
- We may share your information with a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger, or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this policy.
- We may share information with any other person with your consent.
Please be assured that we do not sell your information to third parties or use the information for purposes that are incompatible with those set forth in this policy.
Data Security and Integrity
The data is stored in a secure, proprietary and highly confidential database accessible only by Blackwood employees.
We use our best efforts to ensure that data is accurate, complete, current and reliable for its intended use. We use appropriate technical and organisational measures and safeguards to help protect your personal data from unauthorised access, misuse, alteration or loss. Our internal policies and procedures are designed to help ensure we safeguard the privacy and accuracy of all data we collect or process. To the extent that we disclose personal data to clients or third parties, we will request that they properly protect the security and confidentiality of such information and otherwise process such data in accordance with applicable law.
To match candidate profiles to current opportunities we may transfer your personal data to clients and partners in countries outside the EEA. These countries privacy laws may be different from those in your home country. Where we transfer personal data to a country that has not been deemed to provide adequate data protection standards we always have security measures and approved model clauses in place to protect your personal data. To find out more about how we safeguard your personal data as related to transfers contact us on the details below.
How Long We Keep your Data
We only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
When determining the relevant retention periods, we will take into account factors including:
- (a) our contractual obligations and rights in relation to the information involved;
- (b) legal obligation(s) under applicable law to retain data for a certain period of time;
- (c) our legitimate interest where we have carried out a balancing test (see legal basis above);
- (d) statute of limitations under applicable law(s);
- (e) (potential) disputes;
- (f) if you have made a request to have your information deleted; and
- (g) guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information once this is no longer needed.
You have the right to obtain access to your personal data; to have it updated or corrected if it is inaccurate or incomplete; to request that we restrict its processing or remove your data entirely from our system at any time. You may request the transfer of your personal data to a third party or request no further contact from Blackwood. When asked to remove a record from our database, Blackwood will retain minimal information to ensure we do not contact you or collect such information again or to keep a record of any information disclosed to our clients. You have the right to bring a complaint to the relevant data protection authority in your jurisdiction.
If you don’t wish us to hold any data on you or would prefer that we do not contact you for any reason, or if you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, please contact us at firstname.lastname@example.org. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Last updated: 21st May 2018