Who are we?
The Up Group Limited. We provide executive search and network services to clients looking to recruit talent for their businesses.
What does this Policy cover?
We at The Up Group Limited take your personal data seriously. This policy:
• sets out the types of personal data that we collect about you
• explains how and why we collect and use your personal data
• explains how long we keep your personal data for
• explains when, why and with who we will share your personal data;
• sets out the legal basis we have for using your personal data;
• explains the effect of refusing to provide the personal data requested;
• explains the different rights and choices you have when it comes to your personal data; and
• explains how we may contact you and how you can contact us.
What personal data do we collect about you?
We collect the information necessary to be able to find available opportunities and further information needed to assess your eligibility through the different stages of a search process. This information includes CV’s, identification documents, educational records, work history, employment and references.
We may also collect sensitive personal data about you. We only collect sensitive personal data from you, and further process this data, where you have provided it and given your explicit consent for us to do so.
Where do we collect personal data about you from?
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 (see later in this section).
• 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.
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.
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 personal data about our candidates unless this is legally required for recruitment purposes. In our experience, a legal requirement to do so is rare. In such circumstances we will always seek explicit consent before doing so.
The following are the different sources from which we may collect data about you from:
• Directly from you. This is information you provide while searching for a new opportunity and/or during the different recruitment stages.
• From an agent/third party acting on your behalf. e.g. Interim Management Company.
• Through publicly available sources. We use the following public sources:
o Professional networking sites, including, but no necessarily limited to, LinkedIn
o Search engines
o Email finding services that access publicly available data
o Information services (including but not necessarily limited to Pitchbook and Crunchbase)
o Companies House (including Companies House search)
• 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 and why we use your personal data?
We use your personal data to match your skills, experience and education with a potential employer. We will initially collect basic information on you such as contact details, job role and experience and then pass this on to the client in search of personnel. If you are chosen by the client and go through to the next stage we will then be collecting more information from you at the interview (or equivalent) stage and onwards in that manner.
How long do we keep your personal data for?
We keep your information in accordance as follows:
Candidate data: 7 years
Client contact details: 7 years
Who do we share your personal data with?
Your personal data is shared with the client who initiates a search for personnel. The search for which you are considered, to ascertain if you are a good fit for the available position. We may also conduct checks on you to verify the information you have provided and where we do this we may share your information with, we will seek you consent in advance of sharing your information with third parties who conduct said checks.
Will may also share your personal data in the following circumstances:
• 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.
What legal basis do we have for using your information?
For prospective candidates, referees 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 and referees.
If you are shortlisted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case we always ask for your consent before undertaking such processing.
For clients, we may also rely on our processing being necessary to perform a contract for you, for example in contacting you.
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 data necessary, or withdraw your consent for the processing of your personal data, we may not be able to match you with available job opportunities.
Do we make automated decisions concerning you?
No, we do not carry out automated profiling.
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 have 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
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.
Do we transfer your data outside the EEA?
To better match your employee profile with current opportunities we may transfer your personal data to clients and partners in countries outside the EEA. These countries privacy laws may be different from those in your home country. Where we transfer data to a country which has not been deemed to provide adequate data protection standards we always have security measures and approved model clauses in place to protect your personal data. To find out more about how we safeguard your information as related to transfers contact our Finance and Compliance department: Financeandcompliance@theupgroup.com, 18th Floor, Millbank Tower, 21-24 Millbank, London, SW1P 4QP.
What rights do you have in relation to the data we hold on you?
What does this mean?
1. 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.
2. The right of access
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
3. The right to rectification
You are entitled to have your information corrected if it’s inaccurate or incomplete.
4. 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.
5. 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. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability
You have rights to obtain and reuse your personal data 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.
7. 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).
8. The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
9. The right to withdraw consent
If you have given your consent to anything we do with your personal data, 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 data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
• baseless or excessive/repeated requests, or
• further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
How will we contact you?
We may contact you by phone, email or social media. If you prefer a particular contact means over another please just let us know.
How can you contact us?
If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact our Finance and Compliance department: Financeandcompliance@theupgroup.com, 18th Floor, Millbank Tower, 21-24 Millbank, London, SW1P 4QP.