This policy explains how we process personal data within our business delivering search, consulting and assessment services, including how it affects our website: www.starfishsearch.com
1. Who we are
We are Starfish Search Limited. Further information about our firm and our offices can be found by clicking here.
Starfish Search Limited (“we”, “us”) is committed to keeping your information secure and managing it in accordance with our legal responsibilities, under the privacy and data protection laws applicable wherever we operate in the world, as well as the General Data Protection Regulation (Regulation (EU) 2016/679 (“GDPR”) in the European Union (“EU”).
For the purposes of data protection, we are the data controller and we will process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679.
This policy was last updated in June 2019. Please review this policy periodically for any changes.
2. Who this policy applies to
We provide executive search, assessment and leadership services, interim managers and independent consultants (“our services”) to a range of clients. Details of our services can be found elsewhere on this website. This policy applies to you whether you are a candidate for one of our clients, an individual we are assessing as an employee of one of our clients, a client or whether you are a source or a referee in respect of a candidate or an employee of one of our clients.
Additionally, this policy will apply to you if you attend one of our events or have subscribed to receive information about our services or any of our marketing materials.
For the purposes of this policy:
- candidate(s) means an individual who is a candidate, applicant, potential candidate, employee of a client;
- client(s) means any, business, firm, organisation, government body or individual that mandates us to perform any of our services;
- a referee is a person who provides a personal or work reference in respect of a candidate and;
- a source is a person who provides us with information or intelligence about a candidate.
3. Gathering information
Our clients expect that we identify the best individuals to fill roles within their organisations. So, we need to research systems, online databases and other information sources, and talk to many individuals. Besides our clients, these will include referees and sources to help inform our decision-making process.
The nature of our work means we are required to process personal data quickly, confidentially and often without reference to the data subject. Accordingly, we process such data in accordance with the Data Protection Laws, regularly using our legitimate interest where it is not possible or feasible to speak directly with the data subject. Beyond this, consent will be sought for sensitive categories of data as detailed in Section 6, otherwise for general business processing of data we will rely on legitimate interest or performance of a contract.
We collect information from candidates directly when you send us your CV or resume to us via email or post. We also collect information from you when you speak with a Starfish Search Limited employee in any office. We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
4. How we use your personal data
We use the personal data we collect from you for a number of purposes:
- Processing job applications, in partnership with our clients, on whose behalf we are instructed to help fill a job vacancy. This means that if you apply for a specific job, we may pass your details to the relevant client to proceed with the application. As a result, you may receive further direct correspondence from them.
- Searching for relevant candidates for confidential recruitment assignments where our client is not initially named. This means that if we believe you are suitable for a specific role, we may pass your basic details on to the relevant client. If that client agrees that you might be suitable, we will then discuss this with you in more detail. You might be interviewed for the role by one of our consultants. If successful, you might be shortlisted for interview by our client. At this point, we will pass further details to the client and you may receive further direct correspondence from them. By applying for a role with Starfish Search Limited if we progress your application we will be required to pass some data on to our clients, and by applying for a role with us you consent to that data being passed to our clients.
- From time to time, we conduct mapping or research exercises on behalf of our clients. This is to enable them to understand a particular market. Here, we may include certain aspects of your personal data. You will not be contacted by any third party about this unless we first obtain your consent.
- For the performance of a contract, we have concluded with you as an individual, most likely an assessment or coaching programme.
We will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others or, have your permission to do so.
Please be aware that we are not responsible for the data processing activities of others, such as our clients.
We will use client data to perform our services to you and other legitimate business purposes such as marketing.
Source and Referee
We will use source and referee data to perform our services to enable us to obtain your opinions on a candidate.
5. The type of personal data we collect and process
In all cases, we collect and process personal data about you, including your name, address, telephone number and email address. If you do not provide the personal data necessary, or if you withdraw your consent for the processing of your personal data, we may not be able to proceed with an application on your behalf.
If you proceed with a job application, or should we consult you about a role, you may be required to submit additional personal data. For example, date of birth, education and career history and curriculum vitae (CV), or resume. Your CV or resume may contain employment history, education, professional qualifications, memberships, details of papers written, references and referees, amongst other things.
Based on your explicit consent, we will also process any relevant psychometric assessments, psychological tests, or results from such assessments or tests.
From time to time, we may ask you to provide information relating to protected characteristics, such as your race or marital status. We do this for equal opportunity monitoring purposes and from time to time online, but only if that’s admissible under local law. This information is always anonymised and aggregated and will not be revealed to third parties without your specific consent.
We might also collect personal data from third-party databases and other public sources.
As well as basic contact information we will also collect information about your role and other information provided to us by your organisation.
Source and Referee
As well as basic contact information we will also collect information regarding your credentials as a source, details of your relationship/knowledge of a candidate and your opinions of that individual. We may obtain this information directly from you or publicly available information.
What we do
Besides filling leadership vacancies, we also process personal data when we conduct market intelligence exercises to map out particular business sectors or functions to help clients understand the available talent.
6. Sensitive data
From time to time, we will seek your consent to process personal data in respect of certain specific and limited purposes. We will always do this before processing any sensitive personal data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sex life and sexual orientation, genetic and/or biometric data. We encourage you not to provide us with sensitive personal data unless it is specifically requested, and we have your consent.
In some locations, we provide services to individuals, such as assessment and coaching. Here, we will process personal data for the performance of the contract with you. If our services include any psychometric assessments or psychological tests, we will obtain your specific consent.
7. Providing information to others
To help us run this website, and to provide executive search services or assessment services in certain countries, we work closely with trusted partners with whom we need to share personal data. These partners include:
- Our clients, for whom we provide executive search services.
- Our clients, for whom we provide assessment and coaching of their employees in certain countries.
- Prospective clients, where we might need to demonstrate an understanding of a particular market and the individuals that work within it.
Where we share information with such a third party, you will not be contacted by them, unless we have obtained your prior consent.
8. Third parties
We may also provide information to third party service providers who process information on our behalf. This is to help run some of our internal business operations, including email distribution, IT services and customer services. As part of our agreements with them, these third parties are required to process such data securely and only in accordance with our instructions.
Your information may also be shared with organisations located elsewhere in the world. As their privacy laws may not match your home country’s standards, we’ll only make a transfer of data if adequate levels of protection are in place to protect any information held in that country, or the local service provider complies with applicable privacy laws at all times.
Where required by law, we will take measures to ensure that personal data handled in other countries will receive at least the same level of protection as in your home country.
We may sometimes be required to disclose information about you to law enforcement bodies, agencies or third parties, under a legal requirement or court order. We will act responsibly and take account, where possible, of your interests when responding to these requests.
If you are concerned about these arrangements to disclose or share personal data with third parties, you should contact us and ask us not to process your personal data.
9. Keeping information secure
We invest significant resources to protect your personal data, from loss, misuse, unauthorised access, modification or disclosure. However, no system can be 100% secure, and so we cannot be held responsible for unauthorised or unintended access that is beyond our reasonable control.
10. Information about others
11. Keeping your records
We keep your personal data for as long as required to provide our services, and in accordance with legal, tax and accounting requirements. Where your personal data is no longer required, we will ensure it is disposed of in a secure manner. Where required by law, we will notify you when this has happened. Typically data is retained for four years following our last meaningful contact with you.
In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
12. What rights do I have?
The right to be informed
Starfish Search provides fair processing of information by way of this privacy notice.
The right of access
You have the right to obtain confirmation as to whether or not we are processing your data and a right to obtain a copy of the data that we hold. This is known as a Subject Access Request. Please contact us at firstname.lastname@example.org to make a request.
The right to rectification
If any information held is inaccurate or incomplete, you have the right to have that information corrected or deleted, if other parties have been passed the information (such as HMRC) we will, where possible, inform them of the rectification undertaken. Please contact your local Starfish Search contact to make this request.
The right to erasure (also known as the “right to be forgotten”)
You have the right for your information to be deleted. We will oblige as long as there are no reasons for us to keep the information. For example, where we have to keep certain pieces of information for minimum periods in line with legislation.
The right to restrict or object to processing
You have the right to block or restrict processing, this won’t affect the processing done so far, but will stop further processing. For example, if you apply for a role, we will have to keep information on file for a certain period; we can however remove you from our active candidate talent pools if you wish not to be contacted about further opportunities.
The right to data portability
You have the right for your information to be provided in a machine readable format to enable easy transfer between processors. This right is available to personal data provided by you.
The right not to be subject to automated decision making
Please note that no automated decisions, such as computerised candidate profiling, are made based on the information we collect.
The right to withdraw consent
Where we process information based on the data subject’s (your) consent, you have the right to withdraw consent at any time. Please note where you withdraw your consent this will not affect the lawfulness of processing based on consent before its withdrawal nor further processing of the same data under other legal basis such as contract or compliance with a Starfish Search legal obligation
The right to complain
If you wish to discuss your personal data or lodge a concern about the way in which it is handled, please use any of the following details:
If you are unhappy with our response, you have the right to complain to the Supervisory Authority, the details of which are below:
Supervisory Authority: Information Commissioner’s Office (ICO)
Email: email@example.com Telephone: 0303 123 1113
13 About our website
The primary purpose of our website is to provide you with information regarding the services provided by Starfish Search Limited and consultants.
We use the personal data we collect from you on our website for additional purposes such as personalising the look and feel of the website to fit the personal preferences inferred from how you’ve used the site. (See the “Analytics” and “Cookies” sections for more information.)
We may disclose or share personal data with third parties as outlined above to operate the website and provide our executive search services, as well as assessment services in certain countries. If you are concerned about these arrangements, you should not use the website and contact us to ask us not to process your personal data.
Finally, we might also use your data, to help our clients understand who is making use of our website and how their job vacancies are being viewed.
We may use third-party Service Providers to monitor and analyse the use of our Service.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
15 Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Tracking & Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
17 Third party websites
This Policy only applies to this website. If you land on our site from other websites or move to other ones from our website, you should read their separate privacy policies.
18 Contacting us