A. This Policy
This Policy is provided by Eurosearch & Associés (“Eurosearch”, “we” or “us”), and is addressed to individuals outside our organization with whom we interact, including (but not limited to) Candidates, Participants Sources and (together, “you”). Defined terms used in this Policy are explained in Section (M) below.
For the purposes of this Policy, Eurosearch is the Controller. Contact details are provided in Section (L) below.
We may be amend or update this Policy from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to regularly check this page to review any changes we might make in accordance with the terms of this Policy.
1. Collection of personal data
We may collect Personal Data about you from the following sources :
- Data you provide to us: e.g., where you contact us via email or telephone, or by any other means.
- Data in the ordinary course of our relationship with you: e.g., if we offer to connect you with our Clients, we may collect your Personal Data that are related to such Client opportunities, such as your résumé.
- Data you manifestly make public: e.g. from your social media profile(s), if you make a public post about us.
- Third party information: e.g., past employers; referees; educational establishments; online CV services and databases; and law enforcement agencies
- Background check: with your prior express written consent, conduct background checks (including educational checks), in accordance with the protections provided by applicable law.
- Site data: when you visit any of our Sites, your device and browser will automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connection and other technical communications information), some of which may constitute Personal Data.
- Content and advertising information: If you choose to interact with any third party content or advertising on a Site, we may receive Personal Data about you from the relevant third party.
2. Creation of personal Data
We may also create Personal Data about you, such as records of any interviews you attend. These Personal Data help us to conduct our operations and manage our workforce.
3. Personal Data you provide about others
In some circumstances, you may provide us with Personal Data about others. For example, you might act as a Source and provide comments on a Candidate or Participant. Whenever you provide any such Personal Data, we rely on you to ensure that you have a lawful basis for providing such Personal Data to us, and that you have complied with applicable law and with the terms of this Policy. If you are unable to do so, please refrain from providing such Personal Data to us.
4. Categories of personal data we may process
The categories of Personal Data about you that we may Process include:
- Personal details: given name(s); preferred name; gender; date of birth / age; nationality; photograph; marital status; job title; employer entity; department; salary and compensation details.
- Contact details: home address; work address; home telephone number; work telephone number; work mobile number; personal mobile telephone number; personal email address; work email address; details of Personal Assistants, where applicable; online messaging details; and social media profile details.
- Employment records: dates and details of current and former positions held; details of current and former employers; dates of employment; job titles; job locations; subject matter experience; and details of any employment disciplinary issues or incidents.
- Details of referees: details of referees you may provide, including the relationship that you may have with each such referee, and the duration for which you have known each such referee.
- Background checks and educational checks: details revealed by background checks conducted in accordance with applicable law and subject to your prior express written consent, including details of past employments, educational degrees, details of residence, credit reference information.
- Views and opinions: your views on Candidates or Participants, where applicable.
5. Lawful basis for processing Personal Data
In Processing your Personal Data in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases:
- Consent: we have obtained your prior express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
- Contractual necessity: the Processing is necessary in connection with any contract that you may enter into with us;
- Compliance with applicable law: the Processing is required by applicable law;
- Vital interests: the Processing is necessary to protect the vital interests of any individual;
- Legitimate interests: we have a legitimate interest in carrying out the Processing, which is not overridden by your interests, fundamental rights, or freedoms.
Where we rely on this legal basis, our legitimate interests are in the management and operation of our business, in the promotion of our business, and in the provision of services to our Clients.
6. Sensitive Personal data
We do not seek to collect or otherwise Process your Sensitive Personal Data, except where:
- The Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
- The Processing is necessary for the detection or prevention of crime;
- The Processing is necessary for the establishment, exercise or defense of legal rights;
- Or we have, in accordance with applicable law, obtained your prior explicit consent for voluntary Processing.
7. Purposes for which we may process your personal data
The purposes for which we may Process Personal Data, subject to applicable law, include:
- Executive search and Recruitment activities on behalf of Clients: recruitment operations; advertising Client opportunities; providing services to our Clients; enabling Clients to understand which Candidates are interested in their opportunities; record-keeping; and performing background checks.
- Leadership consulting services including Executive Assessments, coaching and mentoring, surveys on compensation or relevant topics, succession and organizational planning.
- Interim management assignment to apply transformation roadmap agreed with our client on site
- Provision of services to you: attending meetings with you; attending telephone calls with you; and otherwise communicating with you in relation to those services.
- Our Site: operating and managing our Site; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our Site.
- Newsletters and other marketing communications: subject always to compliance with applicable law, communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and possible opportunities in which you may be interested.
- Communications and IT operations: management of our communications systems; operation of IT security; and IT security audits.
- Health and safety assessments and record keeping; and compliance with related legal obligations.
- Financial management: sales; finance; corporate audit; and vendor management.
- Improving our services: identifying issues with existing services; planning improvements to existing services; creating new services.
C. Disclosure of personal data to third parties
Please note that Eurosearch offices may share your Personal Data with each other, for legitimate business purposes (including providing services to you and operating our Site), in accordance with applicable law.
We may also share aggregate demographic information with our Clients, trusted affiliates and advertisers for the purposes outlined in this Policy. While we make all reasonable efforts to ensure that such information is anonymized, small amounts of your Personal Data may be included.
In addition, we may disclose your Personal Data to:
- Legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- Our Clients, for the purposes of providing services to those Clients, in accordance with the provisions of this Policy;
- Accountants, auditors, lawyers and other outside professional advisors to Eurosearch, subject to binding contractual obligations of confidentiality;
- Third party Processors (such as providers of background checking services), located anywhere in the world, subject to the requirements noted below in this Section (C), and in Section (D);
- Any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
- Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security;
- Any relevant third party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
- Our Site may use third party plugins or content (e.g., social media plugins). If you choose to interact with any such plugins or content, your Personal Data may be shared with the relevant third party.
If we engage a third party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use appropriate measures to protect the confidentiality and security of the Personal Data.
D. International transfer of personal data
Because of the international nature of our business, Eurosearch may need to transfer your Personal Data to ECI network office, and to third parties as noted in Section (C) above, in connection with the purposes set out in this Policy.
For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. In particular, your Personal Data may be disclosed by one ECI office to another, to the extent appropriate, in connection with any Client opportunities in respect of which you are a Candidate, or a Participant to any Leadership consulting service.
Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so on the basis of providing services to you under the contract entered into when you signed up with Eurosearch.
E. Data security
We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law.
You are responsible for the ensuring that any Personal Data that you send to us are sent securely.
F. Data accuracy
We take every reasonable step to ensure that:
- Your Personal Data that we Process are accurate and, where necessary, kept up to date; and
- Any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without undue delay.
From time to time we may ask you to confirm the accuracy of your Personal Data.
G. Data minimization
We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably required in connection with the purposes set out in this Policy.
H. Data retention
We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data are as follows:
- we will retain copies of your Personal Data in a form that permits identification only for as long as:
- we maintain an ongoing relationship with you (e.g., where you are lawfully included in our mailing list and have not unsubscribed); or
- your Personal Data are necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis (e.g., where we maintain a copy of your CV for the purposes of providing you with access to opportunities with our Clients, and we have a legitimate interest in processing the personal data in your CV for the purposes of operating our business and providing those services to you),
- the duration of:
- any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data may be relevant); and
- an additional two month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),
- in addition, if any relevant legal claims are brought, we may continue to Process your Personal Data for such additional periods as are necessary in connection with that claim.
During the periods noted in paragraphs 2)a) and 2)b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:
- Permanently delete or destroy the relevant Personal Data; or
- Anonymize the relevant Personal Data.
I. Your legal rights
Subject to applicable law, you may have a number of rights regarding the Processing of your Personal Data, including the right :
- To request access to, or copies of, your Personal Data that we Process or control;
- To request rectification of any inaccuracies in your Personal Data;
- To request, on legitimate grounds:
- erasure of your Personal Data that we Process or control; or
- restriction of Processing of your Personal Data that we Process or control;
- To object, on legitimate grounds, to the Processing of your Personal Data;
- To have your Personal Data transferred to another Controller, to the extent applicable;
- To withdraw your consent on our Processing your Personal Data,
- To lodge complaints regarding the Processing of your Personal Data with a Data Protection Authority.
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (L) below.
J. Cookies and similar technologies
K. Your obligations
If, and to the extent that, you are a Candidate or Participant, we rely on you to provide us with complete and accurate Personal Data about you, so that we can provide appropriate services to you and to our Clients.
If, and to the extent that, you are a Source, we rely on you to ensure that you are lawfully able to disclose Personal Data to us, as set out in this Policy.
L. Contact details
If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data by Eurosearch, please contact our DPO through firstname.lastname@example.org
- ‘Adequate Jurisdiction’ means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
- ‘Candidate’ means a candidate, or potential candidate, for a position with a Client or an executive interim assignment for a Client
- ‘Client’ means a client of Eurosearch.
- ‘Controller’ means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
- ‘Data Protection Authority’ means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
- ‘Participant’ means any individual participating in a Leadership consulting services.
- ‘Personal Data’ means information that is about any individual, or from which any individual is identifiable. Examples of Personal Data that we may Process are provided in Section (B)
- ‘Personnel’ means any current, former or prospective employee, consultant, temporary worker, intern, other non-permanent employee, contractor, seconded or other personnel.
- ‘Process’, ‘Processing’ or ‘Processed’ means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- ‘Processor’ means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
- ‘Sensitive Personal Data’ means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
- ‘Site’ means any website operated, or maintained, by us or on our behalf
- ‘Source’ means any person that provides any view or opinion regarding the qualities of any Candidate or Participant, for any purpose, including but not limited to the suitability of a Candidate or Participant for a particular role.
Last updated: 01/10/2018