THE UP GROUP PRIVACY AND COOKIE POLICY

Last updated on 1 August 2013

The Up Group Limited (“the Up Group”/ “we”/ “us”) has a strong commitment to protect the privacy of all individuals in respect of which it processes information. This Up Group Privacy and Cookie Policy (the “Policy”) describes how information about you is collected and used by us or shared with others, how we safeguard it and how you may access and control its use.

This Policy applies to visitors to our website located at www.theupgroup.com (the “Site”) and to all users or potential users (clients and candidates) of the Up Group’s services (the “Services”).

Protecting your privacy is paramount to us. Please read the following carefully to understand our views and practices regarding your information and how we will treat it. By using the Site and the Services and or otherwise interacting with the Up Group you consent to us processing your personal data and other information in accordance with this Policy.

OUR PRIVACY MOTO

  • We are transparent about the information we hold about you.
  • We will work with you to keep your information accurate and current.
  • We will do our best to keep your information secure and prevent unauthorised access to it.
  • We will delete or place beyond use your information when it is no longer required to deliver our Services or when you ask us to do so.

For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is the Up Group Limited. We are registered in England and Wales under company number 06376612 and our registered office is located at 18th Floor, Millbank Tower, 21-24 Millbank, London SW1P 4QP..

Our nominated representative for the purpose of the Act is Chloe Turner, Head of Insight.

If you have any questions, concerns or comments, please contact us at info@theupgroup.com.

QUICK GUIDE TO CONTENT

1. How we may collect information about you
2. How and why we use cookies and how you can stop the cookies
3. This is what we do with the information we collect about you
4. We share your information in the following limited circumstances
5. What use do we make of information which is aggregated and anonymised
6. This is how we keep your information secure
7. Here are your rights
8. Consent to processing and transfer of information outside of EEA
9. Third party websites which you access from the Site
10. Changes to our Policy
11. Remember: you can always get in touch with us

1. HOW WE MAY COLLECT INFORMATION ABOUT YOU

We are an executive search firm for senior management roles. We continuously expand our international network of senior online, digital, mobile and technology talent and our focus is on building close, long-term relationships with clients and candidates through delivering a high quality, professional, value-adding service. To do our job well, we need to understand the client’s needs and we need to know our candidates well.

To achieve the above, we create detailed profiles about our candidates so as to understand exactly who they are and where they are at in their professional careers. So how do we do this?

Depending on whether you are a candidate or a client, we may collect and process the following data about you:

  • Information that you provide by filling in forms on the Site or information which you share with us at special events which we host.
  • Information which you share with us by sending us your curriculum vitae and/or by completing questionnaires or answering our questions over email exchanges.
  • Information which you share with us when we meet in person.
  • Information about you which is in the public domain such as information on your LinkedIn profile (or on any other social media platform including Twitter and Facebook).
  • Information which third parties who have worked with you or have otherwise interacted with you, share with us.
  • Information which we request from third parties who have agreed to provide us with a reference about you.
  • Information that you provide when you complete customer satisfaction surveys.
  • Information about yourself, such as demographic information (gender, post code, age, etc.) or certain information about your preferences and interests. If we combine demographic or other information we collect about you with information which personally identifies you, we assure you that we will treat the combined information as personal data.

When you visit the Site or interact with the Services, we (and our other service providers) may use a variety of technologies that automatically or passively collect information about how the Services and the Site are accessed and used (“Usage Data”). Usage Data may include, weblogs and other communication data, browser type, operating system, an estimate of your geographic location associated with your IP address, the page served, the duration of your visit, the time, referring URLs and other information normally transmitted in HTTP requests. Usage Data is statistical data about our users’ browsing actions and patterns, and does not identify any individual. Please rest assured however that we will treat Usage Data as personal data if we combine it with you as a specific and identifiable person.

We combine all the information we have gathered about you and create a confidential profile. This profile also includes our objective views about who you are and where you are at in your professional career. It is important for us to include our views because this is how we exercise our expertise in order to match the right candidate with the right client. If you do not want us to hold information about you and /or create a profile for you in order to, where appropriate, be able to consider you for one of our confidential executive searches, please do not use the Site or the Services or otherwise provide us with information about you.

Please remember that you can also always get in touch with us by emailing us at privacy@theupgroup.co.uk.

Typically, if you are a candidate the information you will share with us or that we may collect will include your name and contact details, information about your employment objectives, past and current employment and professional experience, educational background and language skills. If you are a client or potential client, we may collect your name, contact details, title or position and the products or services requested.

We do not actively collect sensitive information about our candidates unless this is legally required for recruitment purposes. The Act defines sensitive information as information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. If you choose to voluntarily provide us with Sensitive information then we will accept your explicit consent to use such information in the ways described in this Policy or as agreed between us at the point where you choose to disclose such sensitive information.

2. HOW AND WHY WE USE COOKIES AND HOW YOU CAN STOP THE COOKIES

A cookie is a small file of letters and numbers that we put on your computer if you use the Site. By browsing the Site you agree to having these cookies placed on your computer.

Google Analytics cookies

These cookies are used to collect information about how visitors use the Site. We use the information to create reports which help us improve the Site. The cookies collect information in an anonymous form, including the number of visitors to a website, from where visitors to a website have come from and the pages visited. For more information, click here for an overview of how Google deals with your privacy.

If you would prefer not to accept cookies, you can do this by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, please be aware that some functions and features of the Site and/or the Services may not work properly because we may not be able to recognise and associate you with your account.

To find out more about cookies please visit www.allaboutcookies.org

3. THIS IS WHAT WE DO WITH THE INFORMATION WE COLLECT ABOUT YOU

We use the information you provide to us to:

  • provide you with relevant information and services including sharing your information with those of our clients looking for a senior executive for a particular role.
  • ensure that content from the Site is presented in the most effective manner for you and for your computer.
  • carry out our obligations arising from any contracts entered into between you and us.
  • notify you about changes to the Services and the Site.
  • invite you and allow you to take part in special events which we host from time to time.

4. WE SHARE YOUR INFORMATION IN THE FOLLOWING LIMITED CIRCUMSTANCES

Except as set out in this Policy, we will not provide any of your personal information to any third parties without your specific consent. We won’t sell your personal information to anyone.

We may disclose your personal information to third parties:

  • When we are contemplating placing you with one of our clients.
  • If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If the Up Group or substantially all of its assets are acquired by a third party, in which case personal data held by it about its candidates will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
  • To enforce an agreement entered into between you and us or to investigate potential breaches.
  • To protect the rights, property or safety of our candidates, clients or anyone else. This includes exchanging information with other companies and organisations for the purposes of fraud protection, the checking of criminal records and other references.

5. WHAT USE DO WE MAKE OF INFORMATION WHICH IS AGGREGATED AND ANONYMISED

We may combine your Usage Data and/or your personal data with those of other users of the Services and the Site and share or provide this trend information in aggregated and anonymised form with third parties. For example, we may anonymise your personal information and use it in aggregated form in order to report on industry, marketing and employment trends.

6. THIS IS HOW WE KEEP YOUR INFORMATION SECURE

  • We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. We continuously strive, having regard to industry standards, to have in place procedures and technologies to maintain the security of all personal data and confidential data from the point of collection to the point of destruction.
  • We make sure that we have the right physical and technical security, backed up by robust policies and procedures and reliable, well-trained staff.
  • All information you provide to us is stored on our secure servers. All communications will be encrypted using SSL technology.
  • We may provide you with a dedicated account which will be password protected. You are responsible for keeping this password confidential. Please do not share your password or share your account with anyone.

Please remember that the transmission of information via the internet is not completely secure. We will do our best to protect your information but we cannot guarantee the security of your data transmitted to our Site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

7. HERE ARE YOUR RIGHTS

  • You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
  • You can exercise your right to prevent such processing by ticking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at privacy@theupgroup.co.uk.
  • If you ask us we will provide you with all the information we hold about you.
  • If you ask us we will delete or place beyond use all the information we hold about you. We will however have to retain your name so that we can record the fact that you do not want us to retain information about you.

8. CONSENT TO PROCESSING AND TRANSFER OF INFORMATION OUTSIDE OF EEA

We are an international business and therefore our use of your information necessarily involves the transmission of data on an international basis. We have candidates and clients situated all over the world. If you are located in the European Union, please be aware that information we collect about you may be transferred to and processed outside of the European Union. By using the Site and the Service, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to countries outside of the European Union in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside.

9. THIRD PARTY WEBSITES WHICH YOU ACCESS FROM THE SITE

The Site may contain links to and from the websites of our partner networks, advertisers and affiliates or other third parties and the Services may appear on third party websites and online media. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we cannot and do not accept any responsibility or liability for these policies. Please check these policies carefully before you submit any personal data to these websites.

10. CHANGES TO OUR POLICY

Any changes we may make to this Policy in the future will be posted on this page and, where it makes sense, notified to you by e-mail or in another appropriate manner. Please check back to this Policy and your e-mail account from time to time to remain aware of our privacy practices.

11. REMEMBER: YOU CAN ALWAYS GET IN TOUCH WITH US

We really do welcome any questions, comments and requests you may have regarding this Policy. You can contact us by emailing us at privacy@theupgroup.co.uk.