Who are we?
Kea Consultants Ltd, registered address at 6th floor, High Holborn House, 52-54 High Holborn, London, WC1V 6RL
We provide executive search services to clients looking to recruit personnel for their businesses. We also provide salary surveys and talent mapping to clients.
What does this policy cover?
We at Kea Consultants take your personal data seriously. This policy:
- Set outs the types of personal data 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; and
- 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 different stages of the recruitment process. This information includes CV’s, identification documents, educational records, work history, employment and references.
We may also collect sensitive personal data about you in the form of biometric data. We only collect sensitive personal data from you and further process this data, where you have given us 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 stages of the recruitment process.
- From a third party acting on your behalf. E.g Interim Management Company.
- By reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague, a current employer or a current colleague.
- Through publicly available sources. We use the following publicly available sources:
- Linkedin, Xing etc
- Financial media
- Other social networks
- Careers portals
- CV books from universities, business schools, industry bodies and networking organisations
- Companies House
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. Occasionally you may be contacted for events or marketing purposes. If you would like to be removed from our events/marketing database, please let us know by emailing us at [email protected]
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:
(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) statute of limitations under applicable law(s);
(d) (potential) disputes;
(e) if you have made a request to have your information deleted; and
(f) guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information once this is no longer needed.
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.
We also share your personal data internally with the rest of the team, in order to determine whether your profile might also be a good fit for their clients and role they are looking to fill.
What legal basis do we have for using your information?
For prospective candidates, 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, but not limited to, sensitive data such as health information that you or others provide about you. In these cases, 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?
We may make automated decisions about you during the assessment stage of the recruitment process. We put assessment candidates through a structured screening process to assess whether each candidate meets the specific criteria for a particular position. These assessments may be fully automated e.g. online pre-screening tests. As these assessments may result in a candidate being deemed not suitable for a position by means of a solely automated assessment, we only undertake this activity with the candidate’s explicit consent. We also carry out personality profiling on candidates with the candidate’s consent. This will be in relation to specific searches, and we will securely erase the data after a client decision on your candidacy for that search has been reached.
Do we transfer your data outside of 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 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 [email protected]
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 right can be obtained from the data protection regulator in your country.
|What does this mean?
|1. The right to be informed
|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.
|2. The right of access
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
|3. The right to rectification
|You are entitled to have your information corrected if it’s inaccurate or incomplete.
|4. The right to erasure
|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.
|5. The right to restrict processing
|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.
|6. The right to data portability
|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.
|7. The right to object to processing
|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).
|8. The right to lodge a complaint
|You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
|9. The right to withdraw consent
|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 or email. 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: Kea Consultants, 6th floor, High Holborn House, 52-54 High Holborn, London, WC1V 6RL, or [email protected]
For any requests coming from inside the EU, we have appointed IT Governance Europe Limited to act as our EU Representative. If you wish to exercise your rights under the EU General Data Protection Regulation (GDPR), or have any queries in relation to your rights or privacy matters generally please email our Representative at [email protected] or post your request or query to: EU Representative, IT Governance Europe, The Mill, Newtown Link Rd, Stagreenan, Drogheda, Co. Louth, A92 CD3D, Ireland
When contacting our Representative please ensure you include our company name in any correspondence.