Privacy Policy
Introduction

Welcome to BD Search & Selection’s privacy policy.

BD Search & Selection respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please also use the Glossary at the end of this privacy policy to understand the meaning of some of the terms used.

Important information and who we are

Purpose of this privacy policy
This privacy policy aims to give you information on how BD Search & Selection collects and processes your personal data, including when you access this website or when you engage with us as a customer, a candidate or a supplier.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

We keep this Policy under regular review and update it from time to time. Please review this policy periodically for changes.

Controller
BD Search & Selection is the controller and responsible for your personal data (collectively referred to as “BD Search & Selection”, “we”, “us” or “our” in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Name of Data Privacy Manager: Baljit Dhadda
Full name of legal entity: BD Search & Selection Limited
Email address: baljit.dhadda@bd-search.co.uk
Postal address:
BD Search and Selection
86 – 90 Paul Street
London
EC2A 4NE
Telephone number: 020 3906 7776

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. 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.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections 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 statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, job role.

Contact Data includes email address and telephone numbers.

Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.

Profile Data includes when you access our website.
Marketing and Communications Data includes your preferences in receiving communications about potential opportunities from us and our third parties .

We may request and, with consent, collect Special Categories of Personal Data about our candidates, clients or suppliers (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, gender, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We may collect information about criminal convictions and offences if requested by the Client, however we do not offer this provision as standard.

Information about others
If you provide us with information about other individuals, for example details of a personal contact or referee, you must ensure that they have agreed to you providing us with their details. We would advise you to keep a record of their agreement and provide them with a copy of, or link to, this Policy to avoid any concern.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
as client, request our executive search services;
as a candidate, respond to any enquiry we make with you in relation to our executive search service;
request marketing to be sent to you;
give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your device, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Contact Data and Transaction Data from providers of technical, payment and delivery services.
Identity Data and Contact Data from publicly available sources such as LinkedIN.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances (these are our “lawful bases” for processing your personal data):

For clients and suppliers, where we need to perform the contract we are about to enter into or have entered into with you.

For potential candidates, and for successful and unsuccessful applicants, where it is necessary for our legitimate interests (or those of a third party, such as our clients) and your interests and fundamental rights do not override those interests. This may include where we need to register and store your data in order to provide a service to our clients, and share your data with our client(s) for the purpose of including your details on a shortlist of possible candidates, and following interviews, for follow up communications and for retaining your details, if you agree, for notifying you about future job opportunities.

Where we need to comply with a legal obligation
Search for “Lawful Basis” in the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use personal data of applicants and candidates, contacts at our clients, contacts at our suppliers, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process personal data for more than one lawful ground depending on the specific purpose for which we are using the data. Please contact us if you need details about the specific legal ground we are relying on to process the personal data where more than one ground has been set out in the table below.

For Client / Supplier Contacts

Purpose/Activity
To register you as a new client / supplier contact
Type Of Data
(a) Identity
(b) Contact
Lawful basis for processing including basis of legitimate interest
Performance of a contract with you or the organisation you work for

Purpose/Activity
To process and perform or receive executive search services requested
Type Of Data
(a) Identity
(b) Contact
(c) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)

Purpose/Activity

To manage our relationship with you which will includes:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to provide a review on our website
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Technical
(e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our executive search services)

Purpose/Activity
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data
(a) Identity
(b) Contact
(c) Technical
Lawful basis for processing including basis of legitimate interest
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

Purpose/Activity
To use data analytics to improve our website, executive search services, marketing, client relationships and experiences
Type of data
(a) Technical
(b) Usage
Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity
To make suggestions and recommendations to you about executive search services that may be of interest to you
Type of data
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to develop our executive search services and grow our business)


For applicants / candidates

Purpose/Activity
To process job applications, in partnership with our clients, on whose behalf we are instructed to advertise job vacancies
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Technical
(e) Usage
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with our clients

Purpose/Activity
To monitor equality and understand the diversity of our applicant pool (anonymised data used)
Type of data
(a) Identity
(b) Profile
(c) Technical
(d) Usage
Lawful basis for processing including basis of legitimate interest
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to understand the diversity of our applicant / candidate pool).

Purpose/Activity
To pass on your details to the relevant client.
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Technical
(e) Usage
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with our clients
(b) Necessary for our legitimate interests (to initiate/ facilitate communications between applicants / candidates and our clients).

Marketing communications from us
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising opportunities.

For candidates and applicants, we may use your Identity, Contact and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which opportunities may be relevant for you (we call this marketing).

Opting out
You can ask us to stop sending you marketing messages by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us in connection with candidate applications or as a result of our provision of executive search services to you. .

Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

We only use technical cookies on the site which are strictly necessary.
We use an Adaptive Image system which uses three cookies. These cookies contain information about the screen resolution and are used to calculate the correct size of images between mobile, tablet and desktop. No personal information is stored within these cookies.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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 note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table ‘Purposes for which we will use your personal data’ above.

External Third Parties as set out in the Glossary
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
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.
International transfers

On the rare occasions that we personal transfer your personal data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. 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.

Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 use or 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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our clients (including Contact, Identity and Transaction Data) for six years after they cease being clients for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you
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 that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties
Service providers acting as processors based in the UK who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, accountants, bankers, auditors and insurers based in in the UK, who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. 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. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide executive search services to you. We will advise you if this is the case at the time you withdraw your consent.