Who are we?
Hanover Search Group Ltd of 1 King Street, London, EC2V 8AU - Email: email@example.com / Telephone: +44 (0)207 248 2244.
We provide executive search services to clients looking to recruit personnel for their businesses. We also provide Interim Management, Salary Surveys, Talent Mapping and Leadership Assessment services.
What does this Policy cover?
We at Hanover Search Group Ltd take your personal data seriously. This policy:
- Sets out the types of personal data that we collect about you
- Explains how and why we collect and use your personal data
- Explains how long we keep your personal data for
- Explains when, why and with who we will share your personal data
- Sets out the legal basis we have for using your personal data
- Explains the effect of refusing to provide the personal data requested
- Explains the different rights and choices you have when it comes to your personal data
- 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 that reveals health information or details of ethnic origin. 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:
- Directly from you. This is information you provide while searching for a new opportunity and/or during the different recruitment stages. Or when you submit your details to us via a contact form on our website.
- From an agent/third party acting on your behalf. e.g. Interim Management Company.
- Through publicly available sources. We use the following public sources:
- Search Engines
- Company Websites
- 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 do 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 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:
- Our contractual obligations and rights in relation to the information involved
- Legal obligation(s) under applicable law to retain data for a certain period of time
- Our legitimate interest where we have carried out a balancing test (see legal basis below)
- Statute of limitations under applicable law(s)
- (Potential) disputes
- If you have made a request to have your information deleted
- Guidelines issued by relevant data protection authorities
Otherwise, we securely erase your information where we no longer require your information for the purposes collected.
Who do we share your personal data with?
We share your personal data with the client who has a position to fill, in order to determine with the client whether you are a good fit for the available position. Our clients are in the financial services sector globally.
We may also conduct checks on you to verify the information you have provided or if required for your onboarding process with the client and where we do this we share your information with third party agencies that perform credit reference or Disclosure Barring Service checks. We may also share your information with Talent ID Ltd trading as Hanover Leadership Solutions (HLS) for arranging psychometric or leadership assessments during your recruitment process and you will always be informed.
We also share our personal data with the following companies within the Hanover Search Group:
- Hanover Search Group Ltd in the Republic of Ireland
- Hanover Search US Inc in the US
- Hanover Wealth Management Inc in the US
Your personal data may also be held by our 3rd party data processors such as our hosted CRM provider.
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. 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 go ahead with such processing. We keep a record of these balancing tests. You have a right to and can find out more about the information in these balancing tests by contacting us using the details below.
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.
If one of our clients asks us to invite you to participate in a psychometric or leadership assessment process, the third party assessment provider (Talent ID Ltd or Lumina Learning Ltd) you are referred to will ask for your consent. Records of your responses to and results of such assessments will be shared with you and our client
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
So, what are cookies and why do we use them?
Cookies are files that are recorded in temporary Internet folders on your PC. They're a useful tool as, by recording the way you use our site, they enable us to get to know you better. For example, we’re able to recognise you when you return to the site, identify your preferences so as to provide you with a more personalised service and speed up searches that you conduct when visiting.
Further Detail on Cookies
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies do lots of different jobs, like letting you navigate between pages efficiently remembering your preferences, and generally improve your web site experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.
We can split cookies into 4 main categories:
Category 1: strictly necessary cookies
Category 2: performance cookies
Category 3: functionality cookies
Category 4: targeting cookies or advertising cookies
Category 1 - Strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like register for newsletters, cannot be provided. Please be aware our site uses this type of cookie
Category 2 - Performance cookies
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works. By using our website and online services, you agree that we can place these types of cookies on your device.
Category 3 - Functionality cookies
These cookies allow the website to remember choices you make (such as your user name and password) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymous and they cannot track your browsing activity on other websites. By using our website and online services, you agree that we can place these types of cookies on your device.
Category 4 - targeting cookies or advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisations.
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.
At present we transfer personal data to the following countries outside the EEA:
- Hong Kong
To find out more about how we safeguard your information as related to transfers and to obtain a copy of such safeguard, contact us using the contact details below.
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.
What does this mean?
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
You are entitled to have your information corrected if it’s inaccurate or incomplete.
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
How will we contact you?
We may contact you by phone, email or social media. If you prefer a particular contact means over another, please just let us know.
How can you contact us?
If you are unhappy with how we’ve handled your information or have further questions on the processing of your personal data, contact us here: Hanover Search Group Ltd: 1 King Street, London, EC2V 8AU - firstname.lastname@example.org