Effective date May 2018

About Carmichael Fisher

Carmichael Fisher ('we' or 'us' or 'our') is a global executive search firm headquartered in London United Kingdom with offices in Brussels, Boston, Frankfurt, Hamburg, London, Los Angeles, Paris, Philadelphia, Stockholm and Zurich. Our registered office is at One Aldermanbury Square, London EC2V 7HR and we are a company registered in England and Wales under company number 05866930. We are registered on the Information Commissioner's Office (ICO) Register and act as the data controller and data processor when processing your data.

We gather and process your personal information in accordance with this Privacy Policy and in compliance with the relevant data protection regulation and laws.

Overview

As a retained executive search firm, our main purpose for processing personal data is to support Clients in recruiting executives for their organisations and to place successful Candidates into Client roles. This Privacy Policy explains the key definitions we use in our executive search, the information we collect about you, the lawful basis for processing your personal data, how we share your information, international transfers in relation to your personal data, safeguard measures we have in place to secure your personal data, your rights regarding the data we process about you, how we conduct our marketing activities, changes that may be made to the Privacy Policy and our contact information.

We respect your privacy and our aim is to ensure that the data we process about you is appropriate to perform our services as an executive search firm and in accordance with data protection laws. This privacy policy provides you with the necessary information regarding your rights and our obligations when we process your personal data.

Our contact information

Carmichael Fisher Limited

4th Floor, One Aldermanbury Square, London EC2V 7HR, United Kingdom |

Registered No. 05866930

P. +44 (0) 203 178 2630

Privacy@carmichaelfisher.com

Contents

  • Definitions

  • Information we Collect

  • Lawful basis for processing your personal data

  • How we use your personal data

  • How we share your information

  • International Transfer

  • Safeguard Measures

  • Data Retention

  • Your Rights

  • Special Category Data

  • Cookie Notice

  • Changes to the Privacy Policy

Definitions

"You" are an existing candidate, potential candidate, client contact, consultant/contractor, referee, source or vendor involved in the introduction and/or supply of our executive search.

"Candidate" means an individual (applicant, prospect, existing) who is considered, evaluated or assessed by Carmichael Fisher to fill a temporary or permanent role with a Client.

"Client" means a hiring organisation looking to recruit temporary or permanent executives to whom we provide our executive search service to.

"Client Contact" means an individual who is an employee and responsible owner of the Client.

"Employee" means an individual who holds a position (whether paid or unpaid) of employment at Carmichael Fisher

"Referee" means an individual who provides employment reference for a Candidate

"Source" means an individual who helps us identify and provide market intelligence about a potential Candidate.

"Vendor" means any entity other than Carmichael Fisher that provides products or executive search to Carmichael Fisher to a contract with Carmichael Fisher.

Information We Collect

Candidate Personal Data

Our main purpose for collecting personal data from you (Candidate) is to fulfil our legitimate interest to recruit you into an executive position specified by a Client.

Information You provide to us: You provide information to us when you speak with a Carmichael Fisher Employee, email your curriculum vitae (CV), apply for an advertised role on LinkedIn or communicate with us in any way relating to the Executive search we provide.

You are not obligated to provide Carmichael Fisher with any personal information or participate in our executive search. Therefore, when we collect personal information directly from you, we consider this to be voluntary. If you are unwilling to provide us with certain requested information, please be aware this may limit our ability to consider you regarding the executive search service we provide.

The information we may collect from Candidates typically include;

  • Contact details such as your name, email address and phone number.

  • Curriculum Vitae (CV) information such as your contact details, employment history, educational history, professional qualifications, languages, skill and personal activities.

  • Identification data such as passport information to book your travel (when attending and interview with a Client).

  • Financial information such as bank account details to reimburse expenses incurred in relation to our Executive search (travel, accommodation and/or meal costs when attending an interview with a Client). We may collect financial information to document the expense and reimburse you.

  • Other information such as immigration status and any other relevant information you may choose to share with us. A record of your marketing preference and our contact history with you is also recorded.

Information we collect from third party sources about Candidates: We may collect personal information about you from publicly available sources, and third parties, including under the following condition: (i) Sources may disclose personal information about you; (ii) our Clients may share personal information about you; (iii) we may obtain information about you from publicly available third-party sources (e.g., LinkedIn, news reports, press releases); and (iv) we may source personal information about you from third party data providers (e.g., GatedTalent) (v) and Referees may provide your information for reference checks. When we obtain information about you, from vendors or third-party providers, we ensure they are legally permitted or required to disclose such information to us.

Client and Client Contact Data

Our main purpose for collecting personal data from you (Client, Client Contact) is to fulfil our contractual obligation while we support you in recruiting executives via retained search.

Information Clients provide to us: We require your contact details (such as name, telephone number, email address and job title) to ensure our relationship is efficiently managed.

Collecting information about you is essential to our service and we may collect information when you contact us with a view of providing a service, email us with an interest to work with us, provide us with your business card or other information given to our employees at sales and marketing events, post information on websites, job boards or social media websites and sign a contractual agreement with us.

The information we may collect from Client contact typically include;

  • Contact details: such as your name, email address and phone number.

  • Company information: such as postal address, details of your role, title and responsibilities within the company.

We also collect any feedback or opinion you share with us regarding a Candidate, queries you raise regarding our service and details of resourcing and recruitment requirements you share with us.

Information we collect from third party sources about Clients: We may seek more information about you or your colleagues by way of due diligence or other market intelligence including (i) from third-party market research and by analysing online and offline media; (ii) from attendee lists at relevant events, networking and conferences; (iii) from other limited sources and third parties.

Referee

Information Referees provide to us: We collect and use your contact (name, email address, telephone number) information to secure a reference for our Candidate. We may also collect certain professional details (job title, occupation) and your connection to the Candidate (such as your relationships to, experience with, and opinions about the relevant Candidate). Candidates tend to provide us with this information but we may supplement it with information we collect about you from publicly available sources (such as LinkedIn) or by asking you directly.

Source

Information Sources' provide to us: We may collect and use your contact (name, email address, telephone number) information, professional details (job title, occupation, academic and professional qualifications, and employment history) and information about your connection to the Candidate (such as your relationships to, experience with, and opinions about the relevant Candidate). This information may be collected directly from you and/or publicly available sources (such as LinkedIn).

Vendor

Information Vendors' provide to us: We may collect and use your contact (name, email address, telephone number) information to ensure our working relationship is efficiently managed. The contact details we collect of individuals in your organisation is to enable communication and any financial information we collect is so we can pay for the executive search you provide (if this is part of the contractual agreement between us).

Lawful basis for processing your personal data

Our principal lawful basis for processing your personal data is our legitimate interest to conduct our executive search operations. As noted in the 'Information We Collect' section of this policy, we process your personal information under the legitimate interests when we conduct our research project and collect your data from third party sources such as LinkedIn. Where this is the case, we have carried out a thorough Data Protection Impact Assessment (DPIA) and) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate. We use the legitimate interests' lawful basis for processing our core recruitment activities.

However, we demonstrate compliance with the GDPR and data protection laws by ensuring the right lawful basis is applied to our various processing activities depending on the personal data involved and the context in which it is processed. Our lawful basis for processing your personal data is applied as detailed below.

Data Subject      Lawful basis for processing your information in accordance with Article 6    Processing Activity

Candidate            Consent                                                                                                                       Candidate Engagement

                                                                                                                                                                     Direct Marketing

                             Legitimate interest                                                                                                     Research project

                             Consent and Legal obligation               Booking international travel as required for a Client interview

Client Contact    Consent                                                                                                                      Direct Marketing

                             Contractual obligation                                                                                            Retained executive search

                             Legitimate interest                                                                                                       Initial engagement

                             Legal obligation                                                                                                           Accounting

Referee               Legitimate interest                                                                                                       Reference check

Source                Legitimate interest                                                                                                       Information gathering

Vendor                Legitimate interest                                                                                      Assessment and one-off projects

How we use your personal data

Candidate Personal Data

Executive Search: We use your data to provide our executive search service to our Clients. This includes conducting research projects to assess the market for suitable Candidates, engaging with Candidate to complete our manual screening process, interviewing over the phone or in person as part of our initial assessment against the Client brief, shortlisting Candidates as specified by our Client, supporting Clients with the final appointment process and maintaining contact with appointed Candidates.

Marketing Activities: We may use your data to send you direct marketing information which we have identified as beneficial to you based on our legitimate interest. If you object to receiving our marketing information, we ensure you can actively opt-out by explicitly providing you with our consent notice.

Client and Client Contact Data

Executive Search: We use your data to provide our executive search service to you. This includes engaging with you to confirm our contractual obligation as identified in the retained executive search terms and conditions, contacting you to feedback on research projects via candidate reports, telephone calls and face to face meetings, shortlisting Candidates with you as specified in the brief you provide and supporting you with the final appointment process.

Marketing Activities: We may use your data to send you direct marketing information which we have identified as beneficial to you based on our legitimate interest. If you object to receiving our marketing information, we ensure you can actively opt-out by explicitly providing you with our consent notice.

Referee

Executive Search: We use your data to complete reference checks for Client Candidates. This includes; contacting you to identify your working relationship with the Client Candidate and getting your written feedback about the Client Candidate.

Source

We use your personal data to contact you about potential Client Candidates and Client Contact that you may identify to us based on your current or past working relationship with the Client Contact or Client Candidate.

Vendor

We use your personal data to contact you about services you provide to us as per the contractual agreement we have in place with you.

How we share your information

We share your personal information solely for conducting our executive search.  How we share your information is dependent upon the processing activity involved and may entail any of the following;

Candidates, Clients, Referees, Sources and Vendors

  • Your information may be shared with our Employees based in the USA, Europe and Switzerland. Your information is kept on our secure network and CRM database, and accessible only to our employees worldwide.

  • Your information may be shared 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.

Candidates

  • Your information may be shared with Client Contacts who will need to process your information for the purposes we have described in this privacy policy.

  • Your information may be shared 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, third-party travel agencies, outsourced IT and document storage providers).

Clients

  • Your information may be shared with Candidates during our executive search activities. Unless otherwise informed and in such cases the Candidate will be provided with a Non-disclosure agreement.

Sources and Referees

  • Sources and Referees, we keep your information confidential from Candidates but under limited circumstances, your information may be disclosed to them.

International Transfer

We transfer personal data outside of the EU for the below purpose(s): -

  • Communicating with our international colleagues based in Switzerland and the US

Where we transfer personal information for the above reasons, we use the following measures to safeguard your information - secure access to our network, secure access to our customer relationship management (CRM) database, secure email using Microsoft Office 365. These measures and mechanisms ensure that your personal data is always safe and secure: -

Safeguard Measures

We take your privacy seriously and take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place. We have implemented appropriate security, technical, physical and legal policies and procedures in place to protect confidentiality of the personal data collected and to prevent accidental loss. We will review and assess these security measures to ensure they are up to date with technological and legal developments.

Data Retention

We only ever retain personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We collect and retain your personal data during our active relationship with you (for the duration of the executive search). When this relationship ends, we retain your information to;

  • Meet our legal obligation - We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of three years after which time it will be destroyed.

  • Meet our internal legitimate operations – We will retain your personal data securely for six years.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Your Rights

You have the right to access any personal information that we process about you and to request information about:

  • What personal data we hold about you

  • The purposes of the processing

  • The categories of personal data concerned

  • The recipients to whom the personal data has/will be disclosed

  • How long we intend to store your personal data for

  • If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data, to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

If you exercise you right to object, the changes will be ineffective with respect to the personal data we process about you. We will explicitly notify you of the consequences of the objection or non-objection to the extent required by law. Please be aware that this limit or terminate the Service we provide to you. Please refer to this privacy policy regularly to stay informed.

If you have any questions about your personal data or any issues to raise, please contact Carmichael Fisher at Privacy@carmichaelfisher.com

Special Category Data

Owing to our executive search activities, we sometimes need to process sensitive personal information (known as special category data) about you, to book travel when required to attend an interview with an internationally based Client. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant lawful basis for doing so. Where we rely on your consent for processing special category data, we will obtain your explicit consent through a signature/explicit mechanism. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.

Cookie Notice

A 'cookie' is a small piece of data sent from a website and stored on the user's computer by the user's web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as visited pages.

Cookies are widely used to make websites work, or to work more efficiently, and our site relies on cookies to optimise user experience and for features and services to function properly. Most web browsers allow some control to restrict or block cookies through the browser settings, however if you disable cookies you may find this affects your ability to use certain parts of our website or services.

Changes to the Privacy Policy

We may make amendments to this privacy policy at any time to reflect changes in our business activities that impact on the processing of personal data. The changes to the privacy policy will adhere to the General Data Protection Regulation and relevant Data Protection laws. When changes are made, we will upload the updated version with the effective change date of the document. Where possible or appropriate, we will measure to keep you informed of the changes.

Contact us for more information