Exclusive Associates UK Limited (company registration number 6664105) (Exclusive Associates, “we”, “us” or “our”) is committed to protecting the privacy of our candidates, clients and all users of our website. We want to provide a safe and secure user experience. We will ensure that the information you submit to us, or which we collect, via various channels (including our website, through written correspondence, e-mail, conversations or meetings with our consultants, or through any of our offices or websites globally), is used only for the purposes set out in this policy.
Exclusive Associates acts as the data controller of personal information.
What personal information is collected and processed?
We will collect your personal details, including but not limited to your name and contact details (including with your e-mail address) and other relevant information from your Curriculum Vitae (“CV”). On occasion this will also include sensitive personal information such as details of criminal convictions and ethnic origin. When we receive your details and CV electronically, this may be through a direct application on one of our websites, an application that you have made through a third-party job board, or a direct e-mail to one of our consultants.
It is likely that we will obtain further personal information about you during the course of our relationship with you. This information may be obtained directly from you or from third parties, such as organisations to whom we have provided your CV and who have engaged with you as part of a job application.
How will your personal data be used?
We will hold, use and disclose your personal information, for our legitimate business purposes including:
- to provide our services to you;
- to maintain our business relationship, where you are a client, candidate or user of our website;
- to enable you to submit your CV for general applications, to apply for specific jobs or to subscribe to our job alerts.
- to match your details with job vacancies, to assist us in finding a position that is most suitable for you and to send your personal information (including sensitive personal information) to clients in order to apply for jobs;
- to retain your details and notify you about future job opportunities other than the specific role for which you have contacted us;
- to answer your enquiries;
- to direct-market products and services, advise you of news and industry updates, events, promotions and competitions, reports and other information. Before we do so, you will be given an option to opt-out of such communications and an option to unsubscribe will also be provided with each communication;
- to fulfil contractual obligations with our clients;
- to provide further services to you by sharing your personal information with trusted third parties.
- to release personal information to regulatory or law enforcement agencies, if we are required or permitted to do so;We may process, in accordance with local regulations, certain sensitive personal data (known as special category data in GDPR) where you include it in information you send to us e.g. if you include information about your health, religion or ethnic origin in the CV you send to us. We may also be required to conduct a criminal records check against your details. We have processes in place to limit our use and disclosure of such sensitive data other than where permitted by law.
The Legal Basis for Processing your Personal Information
Under GDPR, the main grounds that we rely upon in order to process personal information of clients and candidates are the following:
(a) Necessary for entering into, or performing, a contract – it will be necessary for us to process your personal data in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us;
(b) Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;
(c) Necessary for the purposes of legitimate interests – either we, or a third party, will need to process your personal data for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website and customer experience, informing you about our products and services and ensuring that our operations are conducted in an appropriate and efficient manner;
(d) Consent – in some circumstances, we may ask for your consent to process your personal data in a particular way.
Who will have access to your Personal Information?
In certain circumstances we will share your personal information with other parties. Details of those parties are set out below along with the reasons for sharing it.
We disclose your personal information to clients who have vacancies for jobs in which you may be interested.
Trusted Third Parties
We will share your personal information and, where necessary, your sensitive personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, such as:
• employment reference checking;
• qualification checking;
• criminal reference checking (as required);
• verification of details you have provided from third party sources; and/or
• psychometric evaluations or skills tests.
We will also share your personal information with third parties who perform functions on our behalf and provide services to us such as:
• professional advisors;
• data analytics providers;
• IT consultants carrying out testing and development work on our business technology systems;
We require minimum standards of confidentiality and data protection from such third parties. To the extent that any personal information is provided to third parties outside the EEA, or who will access the information from outside the EEA, we will ensure that approved safeguards are in place, such as the approved Model Clauses or the EU/US Privacy Shield.
Regulatory and Law Enforcement Agencies
As noted above, if we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain personal information to such bodies or agencies.
New business owners
If we or our business merges with or is acquired by another business or company, we will share your personal information with the new owners of the business or company and their advisors. If this happens, you will be sent notice of such event.
How long will we hold your information?
The length of time we will hold or store your personal information for will depend on the services we perform for you and for how long you require these. As we often support candidates with placements over many years, and potentially throughout their careers, the purpose for which we retain candidate data is often an ongoing purpose. We conduct regular data-cleansing and updating exercises with our candidates to ensure that (1) the data that we hold is accurate and (2) we are not holding data for too long.
Your rights on Information we hold about you
You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
Right of Access
You have the right at any time to ask us for a copy of the personal information that we hold about you. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
Right of Correction or Completion
If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us using any of the methods in the Contact section below.
Right of Erasure
In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
Right to object to or restrict processing
In certain circumstances, you have the right to object to our processing of your personal information by contacting us using any of the methods in the Contact section below. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes.
You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
Right of Data Portability
In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.
You can ask us to transmit that information to you or directly to a third-party organisation.
The above right exists only in respect of personal information that:
• you have provided to us previously; and
• is processed by us using automated means.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.
You can exercise any of the above rights by contacting us using any of the methods in the Contact section below.
Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the details in the Contact section below.
To subscribe to job alert emails, you will be required to provide your name and e-mail address, which will be used for the purpose of keeping you informed, by e-mail, of the latest jobs in your nominated industry and to provide you with industry news and other information related to our services.
Should you decide that you no longer wish to receive this information, unsubscribe links are provided in every job alert email that you receive.
Job alert emails are sent by Exclusive Associates. Where the sender is based outside the EEA your details will be sent to or accessed by that entity to enable them to issue the relevant job e-mail alert to you.
We give you the option of submitting your CV via our website or by providing your CV to one of our consultants. You can do this either to apply for a specific advertised job or for consideration by our recruitment consultants for positions as and when they come up. Your CV will be stored in our database, and will be accessible by our recruitment consultants.
You can update your CV at any time, simply by following the same procedure to submit a new CV. Your old CV will automatically be archived providing the submission details remain the same (for example you submit both CVs using the same email address or you advise the relevant contact of your new submission).
Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. 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 via third party networks; 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.
Exclusive Associates is an equal opportunities employer and a company committed to diversity. This means that all job applicants and members of staff will receive equal treatment and that we will not discriminate on grounds of gender, marital status, race, ethnic origin, colour, nationality, national origin, disability, sexual orientation, religion or age.
If you have any enquires or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact us at Exclusive Associates UK Limited, 6th Floor, International House, 223 Regent Street, London W1B 2QD or via e-mail at: firstname.lastname@example.org.