At Nolan Partners we are committed to protecting your privacy. We will only use the information that we collect about you lawfully (and in accordance with the Data Protection Act 2018).
WHO ARE WE?
We are Nolan Partners Limited (Company Number 05648970). Our address is 1 Duchess Street, London, United Kingdom, W1W 6AN. You can contact us by post at the above address, by email at email@example.com or by telephone on +44 (0)20 3005 4404.
We are not required to have a data protection officer, so any enquiries about our use of your personal data should be addressed to the contact details above.
Our registered company in the USA is Nolan Partners Inc. Our address is 1330 Avenue of the Americas, Suite 23A, New York, NY 10019. You can contact us by post at the above address, by email at firstname.lastname@example.org or by telephone on +1 212 763 0590.
WHAT PERSONAL DATA DO WE COLLECT?
The information about you we may collect, hold and process is set out below:
- Your name
- Your address
- Your email address
- Your telephone number
- CV/work history
- Any job preferences including role, geographical areas and salary
- Any other work related information you provide, for example, education or training certificates.
The information that we collect is submitted to us directly by clients or candidates, from public sites containing contact and CV data, from interviews and interactions with candidates and other connected parties and from online sources.
WHAT DO WE DO WITH YOUR INFORMATION?
This information will have been provided, or will be provided by you or as listed above. In the case of references, these will be from your previous employer or other significant contact. If required medical information may be supplied by a third party such as your doctor, Specialist/Consultant or Occupational Health. The outcome of criminal record checks and security clearance checks, where relevant, will be supplied by the Disclosure and Barring Service in the UK or other external body applicable to the placement.
WHY DO WE COLLECT THIS INFORMATION?
The above information is used to provide the best services to our clients in finding the most suitable candidates for their business. The details provided by candidates allows us to match the requirements requested from our clients in order to fulfil this brief. Any information provided by a candidate is solely for the purpose of matching you to a position or a current brief. We may hold your information on our database in line with our retention policy (available upon request) to keep you informed of future opportunities as they arise. Any objection to processing of this type can directed to the Who Are We section of this policy.
Our website uses “Cookies” which are text files placed on your computer, to collect standard internet log information and visitor behaviour information in an anonymous form. Cookies can contain information such as your user ID and the pages that you have visited.
You may refuse to accept cookies by activating the setting on your web browser which allows you to refuse the setting of cookies. For more information about cookies and how to disable them http://www.allaboutcookies.org/.
Nolan Partners employ the services of Google Analytics to help analyse how users interact with this website. The tool uses “cookies” and the information generated by the cookie about your use of the website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the website and to compile statistical reports on website activity for Nolan Partners Ltd and Nolan Partners Inc.
We will never (and will not allow any third party to) use the statistical analytics tool to track or to collect any Personally Identifiable Information (PII) of visitors to our site. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link, or seek to link, an IP address with the identity of a computer user. We will not associate any data gathered from this site with any Personally Identifiable Information from any source unless you explicitly submit that information via a fill-in form on our website.
You may choose to accept or decline cookies. Most Web browsers automatically default to accept them, but you can usually modify your browser setting to decline cookies. If you reject cookies by changing your browser settings then be aware that this may disable some of the functionality on our Website.
THE LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA
Under GDPR, the main grounds that we rely upon in order to process personal information of clients and candidates are the following:
- Necessary for entering into, or performing, a contract– in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;
- Necessary for compliance with a legal obligation– we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;
- Necessary for the purposes of legitimate interests– we will need to process your personal data for the purposes of our legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and enquiries from you or our clients. This helps to ensure that our operations are conducted in an appropriate and efficient manner. We collect, process and distribute candidate data with the intent of identifying and presenting suitable candidates for Executive and Board roles with Clients who have indicated a requirement for such roles.
- Consent – in some circumstances, we may ask for your consent to process your personal data in a particular way.
HOW WE HOLD THE INFORMATION
All the personal data we have is stored on our systems inside the European Economic Area.
DISCLOSURE OF YOUR INFORMATION
Candidates CVs and related information will be shared or sent to prospective employers (our clients). Once a placement is secured then additional information will be provided to them to enable the placement to proceed. A number of employers will usually be located inside the European Economic Area (EEA) but may be outside of the EEA. Personal data shall not be transferred to a country or territory outside the EEA unless that country or territory ensures an adequate level of protection or the appropriate safeguards are in place for your rights and freedoms. Before such a transfer takes place outside of the EEA, we will provide you with further information concerning this.
Nolan Partners Ltd may also share your information with Nolan Partners Inc, an affiliated company of Nolan Partners Limited, for the purpose of finding you a suitable role.
HOW LONG DO WE KEEP YOUR INFORMATION FOR?
Your data will be retained for no longer than is necessary and in accordance with our Data Retention Policy which is available upon request.
YOUR RIGHTS AS A DATA SUBJECT
GDPR has extended the rights of the Individual. Details of these rights and how to exercise them are set out below. In order to act upon a request we will require evidence of your identity.
Right of Access
You have the right to ask for a copy of the personal information about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reason for doing so.
Right of Correction or Completion
If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us using the details in the Who we are section above.
Right of Erasure
You have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
Right to object to or restrict processing
In certain circumstances, you have the right to object to our processing of your personal information by contacting us using any of the methods in the Who we are section above. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests.
You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
Right of Data Portability
You have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.
You can ask us to transmit that information to you or directly to a third party organisation.
The above rights are subject to limitations and exceptions. We will provide legitimate reasons if we are unable to comply with any request for the exercise of your rights.
To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the details in the Who we are section above.
YOUR RIGHT TO COMPLAIN
If you have a complaint about our use of your information, you can contact the Information Commissioner’s Office via their website at www.ico.org.uk/concerns or write to them at:
Information Commissioner’s Office
We regularly review and, if appropriate, update this privacy notice from time to time, and as our services and use of personal data evolves. If we want to make use of your personal data in a way that we haven’t previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.