MERLIN WRIGHT ASSOCIATES LTD
ABOUT THIS POLICY
It also explains your privacy rights and how the law protects you including how we comply with the General Data Protection Regulation (“GDPR”) and other related legislation which relates to the use of personal data.
We may change this policy from time to time by updating this page.
Additional information may be provided on particular pages of this website, for example, on any specific pages where we collect personal data and you should also refer to those.
We operate cookies on our website. Cookies are small text files which are transferred from this website and stored on your computer’s hard drive. They enable a website to “remember” who you are.
Most browsers are automatically set to accept cookies but if you are using Microsoft’s Internet Explorer or Netscape Navigator, you should be able to configure your browser to restrict cookies or block all cookies if you wish. This may, however, affect your ability to log into and use certain areas or our site. Browser-specific instructions on how to restrict or block cookies may be found on the IAB’s website at http://www.allaboutcookies.org.
We use session cookies (which are temporary cookies) to keep track of your session when you use our website. Session cookies are deleted when you close your browser. We do not use persistent cookies which remain on your browser until you delete them. No cookies on our site are served or used by third parties. We do not use “spyware”, that is web bugs or hidden identifiers or other similar devices to gain access to information, store hidden information or to trace activities of users. More information on cookies can be found at http://www.allaboutcookies.org.
For the purposes of this website and the information collected through it, Merlin Wright Associates Ltd is the data controller and is responsible for your personal data. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us, using the following details:
By email: email@example.com
By post: Merlin Wright Associates, 7 Airport West, Lancaster Way, Leeds, LS19 7ZA, UK.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, like the opportunity to assist you with any concerns before you approach the ICO so please contact us in the first instance using the details above.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you provide us with information about any other person, for example any other individuals within your organisation or your business partners, then you
This website may include links to third-party websites, for example we provide links to our social media pages and to the page of the charity (Candlelighters) which we support. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. You should read any policies and other statements on such websites carefully.
THE DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified. It does not include data which has been anonymised such that a person’s identity is removed.
We may collect, use, store and transfer different kinds of personal data. We operate on a business to business basis with our client organisations and accordingly, a lot of personal data we use is provided to us in the context of our business operations and the business and resourcing operations of our clients. We do however, also collect, use and disclose personal data relating to candidates and enquirers.
The categories of personal data which we use include:
- Identity and Contact Data such as names, titles and other identifiers together with addresses, email addresses and telephone numbers.
- Employment Data such as a candidate CVs, employment references and career history.
- Communications Data including preferences about receiving news and marketing communications about our business and sector.
HOW IS YOUR PERSONAL DATA COLLECTED?
We collect personal data in a number of different ways. For example, we may collect personal data directly through this website (including via our ‘Contact’ page), by email, over the phone or through face to face interactions.
The personal data we collect is usually provided by you directly though in some cases may come from another person. For example, in the case of our clients, we may receive information from your colleagues and other contacts and in the case of candidates, we may receive information from third party referrers or referees.
We also obtain personal data through our own research, for example to obtain information about our clients and potential candidates for the purposes of carrying out our services. Any such research is carried out only via publicly available sources unless you otherwise provide third party contact information such as a referee’s details.
PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. The information below explains the purposes for which we use different categories of personal data and the legal basis or bases which we believe applies to those uses. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Operating our website
We may process your identity and contact data and technical data, for the purposes of administering and operating this website. This may include troubleshooting, data analysis, testing, system maintenance and support, as well as our use of Google Analytics. This helps us to continually improve this website and the services we offer. We process your data in this way on the basis that this is necessary for our legitimate interests in managing, administering and improving this website and our services, and for network security.
Providing services to our clients
Where you are a representative of an organisation we provide our services to, we will process your identity and contact data in order to deliver such services to the organisation including contacting you with updates and candidate details, dealing with your enquiries as well as to deal with any ancillary matters such as sending you invoices and administering payment from the organisation. We process your data in this way on the basis that it is necessary to do so for the performance of the relevant contract that is in place between us and the organisation you represent.
Where you are an individual we approach, or if you approach us as a potential candidate for placement in a role with one of our client organisations, we will process your identity and contact data and your employment data to assess your suitability as a candidate for any actual or speculative placements and interview processes. This will also include for the purposes of assessment, executive search, CEO succession planning and interim appointments depending on the specific circumstances in each case.
We may also use this data to put you in contact with our client organisations as potential employers, and we may transfer your data to those organisations, for example to provide them with a copy of your CV for assessment of your suitability to a role, or to arrange an interview with you. We process your data in this way on the basis that it is necessary for our legitimate interests in the operation of our business, and to assess your suitability for potential employment placements of interest to you.
Disclosure of data to third parties
We may process your identity and contact data and technical data to ensure that our third-party providers can perform their obligations to us. Processing in this way is necessary for our legitimate interests in ensuring that such third-party providers, such as our IT providers, can ensure the proper function of our website.
We will only send referee requests to those referees whose details you provide to us. Disclosure of those details will only be done with your consent.
If you contact us with a comment, enquiry (for example through our ‘Contact’ page) or if you want to speak to us, we will use your identity and contact data in order to respond to you. Processing your data in this way is necessary for our legitimate interests in the operation of our business, in order to respond to your enquiry.
We do not sell your data or transfer it to any other person other than as set out in this policy.
Updates and news about roles
We may contact you with our appointment and placement news where we think such news or communications may interest you or where you have subscribed to receive them. To do this we will use your identity and contact data, and may also use your technical data and communications data. You might also wish to subscribe to our newsletter. We process your data in this way as it is necessary for our legitimate interests to develop, market and promote our services and the roles offered by our clients.
In addition, we may disclose information about you to the extent that we are required to do so by law, in connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention) and/or where we may otherwise do so in accordance with applicable data protection legislation.
IF YOU DO NOT PROVIDE PERSONAL DATA
Please note that where we need to collect personal data by law, under the terms of a contract we have with the organisation you represent or for another lawful and proper reason and you decide not to provide that data, we may not be able to fully perform our obligations in accordance with our contract, provide you with the information you require or otherwise properly deal with your request as you might expect.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please also note that we may process your personal data without your knowledge or consent, in compliance with the above, where this is required or permitted by law.
If you would like further information about how we use personal data and the purpose which we might use it for, please contact us.
DISCLOSURES OF YOUR PERSONAL DATA
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Similarly, we only disclose your data to candidates on the basis that our client organisations use that data, specifically, contact data and employment data in relation to their assessment of and communications with a candidate, as part of their own recruitment practices.
DATA TRANSFERS OUSIDE OF THE EU
To deliver our services, it is sometimes necessary for us to share your personal information outside of the European Union (Switzerland only), for example if you are a representative of one of our client organisations and are based there. Similarly, if you are a candidate, your personal information may be shared with a client based In Switzerland so that they can consider you for relevant roles.
It may also be necessary for us to share your personal information with service providers and sub-contractors based outside of the EU from time to time.
Any such transfers are subject to special rules under European and UK data protection law. We take measures seeking to ensure the secure transfer of your personal information, in compliance with those laws.
The disclosure of personal data in those circumstances will only be made where we have put in place particular safeguards for the transfer of the data. In the majority of cases, this we will be where we have put in place appropriate contractual arrangements with the recipients of data outside of the EU which include requirements aimed at ensuring that that data remains secure. In the case of Switzerland, it is also worth noting that this will involve a transfer of personal data to a country which the European Commission has determined has appropriate arrangements in place for the safeguarding of personal data in terms of the legal regime operating in that country.
Please contact us using the details above if you would like more information about the arrangements we have put in place for the protection of personal data outside of the EU.
We take reasonable, technical and organisational precautions and security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. However, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
In addition, we limit access to your personal data to those employees, agents, client organisations contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Our data retention policy is to review and refresh personal data on a cycle, dependent on the purpose for which it is held. This data will be reviewed on this cycle to determine its ongoing necessity and to ensure that it is still sufficiently accurate and up to date either through direct confirmation with the you or through third party verification. Our policy is therefore to retain candidate data for all role types for a period of ten years.
In some circumstances, we may anonymise 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 policy to you.
We also use Google Analytics to improve the quality of our website and services and to analyse how the website is used. With the exception of an IP address, the information which we collect and use via such means is anonymous traffic data. We do not undertake data profiling.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Those rights are listed below. Please contact us if you would like to exercise any of them. You have the right to:
- Request access to your personal data (a “data subject access request”). This means you can receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. You can ask us to remove personal data where there is no good reason for us continuing to process it. You also have this right where you have successfully exercised your right to object to processing, where we may have processed your data unlawfully or where we are required to erase your personal data to comply with law. We may not always be able to comply with your request where there are particular legal reasons.
- Object to processing of your personal data where we rely on a legitimate interest basis and if the processing impacts on your fundamental rights and freedoms. You can also object to direct marketing. In some cases, we may demonstrate that we have grounds to process your data which override your rights and freedoms.
- Request restriction of processing. You can ask us to suspend the processing of your personal data: if you want us to establish the data’s accuracy; where our data use is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer need it, to establish, exercise or defend legal claims; or you have objected to use of data but we need to verify whether we have overriding legitimate grounds to use it.
- Request a data transfer. We will provide to you, or your chosen third party, your personal data in a structured, commonly used, machine-readable format. This only applies to automated information which you provided consent for us to use or necessary to perform a contract with you.
- Withdraw consent at any time where we rely on consent to process your personal data. This will not affect the lawfulness of processing carried out before you withdraw your consent.
EXERCISING YOUR RIGHTS
You will not have to pay a fee to access your personal data (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you to clarify your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests in which case we will keep you updated.