The Data Protection Policy employed by RSA Consulting Ltd (RSA) has been developed as an extension of our commitment to combine the finest quality services with the highest level of integrity in dealing with our clients, candidates, suppliers, associates and staff. The Policy guides how we collect, store and use information about individuals and organisations. It will be continuously assessed against new technologies, business practices and the changing needs of everyone we deal with.
Our Data Protection Policy recognises two kinds of personal data that deserve different levels of protection:
- Personally-Identifiable Information includes, for example, e-mail addresses, billing information, employment status and ‘click stream’ data that tracks visitor activity on a Web site or online service.
- A subset of that category, Sensitive Data, deserves additional safeguards. Sensitive Data includes, by way of example, Clients’ confidential data, individuals’ home telephone numbers, Bank Account, Income Tax and National Insurance numbers, interview notes, CV’s, etc. If your relationship with us includes providing RSA with Sensitive Data, we will protect that information with extra care. We will not distribute Sensitive Data outside of RSA, if you so request, and will give you the chance to opt out of sharing this information within our own organisation.
RSA collect Personally-Identifiable Information and Sensitive Data only when there is a legitimate business need to do so.
Our Policy provides the following:
- Notice: We will inform you about why we are collecting Personally-Identifiable Information and how we intend to use it. We need to collect and store your name, address, and other basic Personally-Identifiable Information, for example, to provide you with the service you requested, as well as for billing purposes. This information also enables us to develop and customise services better to meet your needs and preferences and to bring to your attention job etc. opportunities from RSA and occasionally other sources that may be of interest to you.
- Opt Out: From time to time, we are approached by companies and organisations that have a product or service that we believe may be of interest to you. We may share your Personally-Identifiable Information with these companies in an effort to help you find these resources. We will, however, always gain your permission before disclosing Personally-Identifiable Information to third parties that are not affiliated to RSA.
- Security: We will maintain appropriate safeguards to ensure the security, integrity and privacy of your Personally-Identifiable Information.
- Review and Correction: We are continuing to enhance our procedures to enable you to review and correct, upon request, the Personally-Identifiable Information we collect from you. Currently, we need you to make such a request in a manner that can be verified.
- Registration: RSA is registered with the Office of the Information Commissioner (formerly the Data Protection Commissioner) www.dataprotection.gov.uk, number Z5582962. This grants RSA the right to store and process personal data on individuals for commercial use within the EU and other selected countries such as Switzerland and the Nordic countries that have also subscribed to the EU controls on data use.
RSA will not sell personal data in any form, including mailing lists. All its data are for internal use only: clients only discover candidates’ identity when they give permission. From time to time RSA conducts surveys on market trends, pay levels etc. Individual responses are never published or revealed – only summarised data are released.
RSA will continue to oversee implementation of and compliance with our Policy and will adapt the Policy to reflect changes in technology and the expectations of everyone we deal with. To ensure that we are following our stated Policy, we also conduct periodic and random audits of our Web sites and other systems.
The RSA Data Protection Policy has been developed out of respect for the privacy preferences and choices of our candidates, suppliers customers, associates and staff. We have established procedures to ensure that every reasonable effort is made to address your concerns. If you have any questions or comments on RSA and its data protection policy please contact one of our Directors. If you have a complaint about our handling of data, you have the right to involve the Information Commissioner – but please inform us first, preferably by e-mail, so that we may have the opportunity to address any issues directly with you.
1.1 We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.
2. How we use your personal data
2.1 In this Section we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4 We may process your personal data that are provided by you in the course of the use of our services (“service data“). The service data may include name, address, CV information and remuneration details. The source of the service data is you. The service data may be processed for the purposes of providing our services and communicating with you. The legal basis for this processing is our legitimate interests, namely carrying out Executive Searches on behalf of our clients, or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.7 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, as an Executive Search company.
2.8 We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.9 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.10 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies insofar as reasonably necessary for the purposes set out in this policy.
3.2 In addition to the specific disclosures of personal data set out in Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA)].
4.2 We and our other group companies have offices and facilities in United States of America and Singapore. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the European Commission].
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain and delete your personal data as follows:
(a) Personal data will be retained for as long as we consider it to be commercially relevant and potentially beneficial to both you and us. In our opinion when and if the data becomes non-relevant and therefore has no potential to be beneficial it will be deleted from our systems.
5.4 Notwithstanding the other provisions of Section 6 below, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 From time to time we may notify you of changes to this policy.
7. Your rights
7.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the supply of appropriate evidence of your identity [(for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address)].
7.2 We may withhold personal information that you request to the extent permitted by law.
7.3 You may instruct us at any time not to process your personal information for marketing purposes.
7.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
8. Your rights
8.1 In this section we have summarised the rights that you have under the new General Data Protection Regulations that come into effect on May 25th 2018. Some of the rights are quite complex and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access any of your personal data we hold;
(b) the right to rectification of any inaccurate data we hold.
(c) the right to have the data deleted.
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent to your personal data being held on our systems.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: [the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: [for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims].
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
11. Cookies used by our service providers
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13. Our details
13.1 This website is owned and operated by us – The RSA Group
13.2 We are registered in England and Wales under registration number 1803896 and our registered office is at 85 Tottenham Court Road, London, England, W1T 4TQ
13.3 Our principal place of business is at 85 Tottenham Court Road, London, England, W1T 4TQ
13.4 You can contact us:
(a) by post, using the postal address given above
(b) Using our website contact facility at https://www.thersagroup.com/contact/
(c) by telephone, on +44 (0)20 3818 8858
(d) by email, using the email address published on our website from time to time – email@example.com
14. Data protection officer
14.1 Our data protection officer’s contact details are: firstname.lastname@example.org