We provide executive search and interim services to clients looking to recruit personnel for their businesses.
What does this Policy cover?
We at Wilton & Bain take your personal data seriously. This policy:
o sets out the types of personal data that we collect about you
o explains how and why we collect and use your personal data
o explains how long we keep your personal data for
o explains when, why and with who we will share your personal data;
o sets out the legal basis we have for using your personal data;
o explains the effect of refusing to provide the personal data requested;
o explains the different rights and choices you have when it comes to your personal data; and
o explains how we may contact you and how you can contact us.
What personal data do we collect about you?
We collect the information necessary to be able to find available opportunities and further information needed to assess your eligibility through the different stages of recruitment. This information includes CV’s, identification documents, educational records, work history, employment and references. We may also collect sensitive personal data about you if you have explicitly shared it with us. We only collect sensitive personal data from you, and further process this data, where you have given your explicit consent.
Where do we collect personal data about you from?
The following are the different sources we may collect personal data about you from:
o Directly from you. This is information you provide while searching for a new opportunity and/or during the different recruitment stages.
o From an agent/third party acting on your behalf. e.g. Interim Management Company.
o Through publicly available sources. We use the following public sources:
- Company Websites
o By Reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer.
How and why we use your personal data?
We use your personal data to match your skills, experience and education with a potential employer. We will initially collect basic information on you such as contact details, job role and experience and then pass this on to the client in search of personnel. If you are chosen by the client and go through to the next stage we will then be collecting more information from you at the interview (or equivalent) stage and onwards in that manner.
How long do we keep your personal data for?
We keep your information in accordance as follows:
Candidate data: 5 years with no contact
Interim Manager data: 5 years with no contact, if no contractual arrangements with Wilton & Bain. 7 years if there are contractual arrangements with Wilton & Bain.
Client contact details: 5 years with no contact
Who do we share your personal data with?
Your personal data is shared with the client who initiates a search for personnel. The search for which you are considered, to ascertain if you are a good fit for the available position. We may also conduct checks on you to verify the information you have provided and where we do this we may share your information with vetted third parties, that we can disclose if used.
What legal basis do we have for using your information?
For prospective candidates, interim managers, referees and clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees.
If you are shortlisted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case, we 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, for example in contacting you.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary, or withdraw your consent for the processing of your personal data, we may not be able to match you with available job opportunities.
Do we make automated decisions concerning you?
No, we do not carry out automated profiling.
Do we transfer your data outside the EEA?
To better match your employee profile with 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 data to a country which 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 information as related to transfers contact us on GDPR@wilton-bain.com
What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.