Privacy & GDPR Policy
PRIVACY POLICY MCV ASSOCIATES LTD
Under General Data Protection Regulations from 14 May 2018
Who are we?
MCV Associates Ltd assists clients in identifying and attracting high calibre executives for senior level roles across a range of vertical sectors and geographies. We provide these services to both the executive search sector and to clients directly, who are looking to fill a position.
Our registered office address is MCV Associates Ltd, First Floor, Telecom House, 125-135 Preston Road, Brighton, East Sussex BN1 6A.
We are registered with the Information Commissioner’s Office and hold a Certificate of Registration Number ZA363066. This is renewed annually.
This Policy complies with General Data Protection Regulation (GDPR). We may update this Policy from time to time and any updates will be shown on this document. Changes and clarifications will take effect immediately upon their posting on the website. This policy was last modified on 12 February 2024.
We act as a data processor to our clients, mainly executive search consultants/recruitment firms who are working on behalf of an end client with a position to fill. This means we collect data from you on their behalf and we will either store the data directly onto their systems or, where this is not possible, store your information on our systems on their behalf. Our clients are fully GDPR compliant and we abide by their policies. You will be able to obtain more information on their privacy and GDPR policy from their websites or by writing to them.
In some instances, we are the data controllers ourselves (for example where you contact us directly and supply us with your CV for future purposes or where we work directly with end clients who have a position to fill). We are committed to protecting your personal data and do our utmost to provide a safe and secure environment where we deal with your information. Please see our GDPR policy below:
What personal information do we collect about you?
We collect the information necessary to be able to help us assess your interest and suitability for a particular job opportunity and further information needed to assess your eligibility through the different stages of recruitment. This information can include any of the following: your name, contact details, salary details, educational records, work history, current employment, CV.
Please note that especially CVs can include very sensitive data like information about ethnic origin, religious, political, philosophic convictions, memberships in unions or political parties and physical or mental health. We recommend not to give any indication or information about those subjects. In case you inform us about such subjects you acknowledge and agree that we can save, use and forward those data in accordance with this data protection declaration.
Where do we collect personal information about you from?
- Directly from you. This is information you provide while searching for a new opportunity (for example when you provide a CV) and/or during the different stages of the recruitment process.
- From an agent/third party acting on your behalf.
- Through publicly available sources. We use a range of public sources including:
o LinkedIn
o Xing
o Google
o Facebook & Twitter
o Company Web sites and other social media platforms
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 do we use your personal information and what legal basis do we have for using such information?
To provide a requested service or carry out a contract with you
Where we are asked by clients under our legitimate business interest to suggest candidates who may be appropriate for a specific role.
Where we have a legitimate interest
- For prospective candidates 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 .
- Any data we collect and process as part of our services or from you directly will only be used in relation to our executive research and search assignments or projects. Legitimate interest means that we do not require consent from the data subject.
- We use certain personal data to determine which candidates might be worth approaching for a particular role. This is necessary for our legitimate interests as a research company. We do not use any sensitive personal data without ensuring we have another basis for such processing.
- We may use certain personal data with a client or show a profile within the context of the assignments or projects.
Where we have your consent
Where we have contacted you to discuss an opportunity and you have expressed an interest and subsequently provide further, personal data (such as your CV) which may sometimes include sensitive personal data, we will share this with our client with your consent. Where you have sent us your CV for potentially relevant future assignments or where you have provided a CV for a specific assignment but thereafter gave us permission to keep your details on our files, we will always ask for your consent before sharing it with a third party.
Where we have a legal obligation
Where we are required by legal authorities or statutory requirements to disclose information under binding legal obligations.
How long do we keep your personal information for?
We keep your information for the following periods, whether you are based within the EEA or outside:
Candidate data:
Up to five years.
Client data:
Up to five years.
After this time, if we have had no further contact with you, we will minimise the data held.
Who do we share your personal information with?
We share your personal information with the client who has a position to fill and/or with the search consultant seeking to fill a position with their client in order to determine with the client whether you are a good fit for the available position.
We share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as search and research consultants, IT consultants carrying out testing and development work on our business technology systems. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.
We will never use your data for any other reasons beyond those explicit purposes
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 information necessary, or withdraw your consent for the processing of your personal information, we may not be able to match you with available job opportunities.
Do we transfer your personal information outside the EEA?
We sometimes transfer your personal information outside the EEA when we are retained on assignments to fill a role based with a client outside of the EEA or to an international client. We operate in Countries of which the ICO has made a “positive finding of adequacy”
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 information. Further information and advice about your rights can be obtained from the data protection regulator in your country.
Your rights and what do they mean?
- 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).
- 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.
- The right of access
You have the right to obtain access to your information (if we’re processing it).
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
- The right to rectification
You are entitled to have your information corrected if it’s inaccurate or incomplete.
- 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.
- 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.
- The right to data portability
You have rights to obtain and reuse your personal information 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.
- The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal information with your national data protection regulator.
- The right to withdraw consent
If you have given your consent to anything we do with your personal information, 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 information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal information for marketing purposes.
We act on requests and provide information within one month of receiving the request.
How can you contact us?
Please contact the Data Protection Officer:
Miranda Vos
+44 (0) 20 8257 3926
Miranda.vos@mcvassociates.co.uk