At Lucena, we take data privacy seriously and are committed to safeguarding the privacy of our Clients, Contacts and Visitors to our Website. This Privacy Notice describes when and why Lucena collects your personal information, how we use it, the limited conditions under which we may disclose it to others and how we keep it secure – we will also let you know what choices you have with respect to information about you.
This Notice covers personal information we collect:
- i) in connection with our search, and other services and in the usual course of our business - whether we are in the process of assessing or engaging you as a Candidate for a role with a Client, in the process of providing executive search services to you as a Client, employing your services as a Supplier, or engaging with you as a Source or Referee in relation to one of our Candidates;
- ii) and when you visit our Website (http://www.lucenasearch.com)
This Privacy Notice does not cover the data collection or processing practices of other web pages to which we may provide links on our Website or through other communication channels.
THE PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
We collect from you, information including personal data necessary to assess your suitability for an executive role with a Client, and/or to actively search for a role on your behalf. This information typically includes:
- • Résumé data: such as your employment and educational history, professional qualifications, as well as languages and other skills and activities.
- • Contact details: such as your name, e-mail address, and telephone number.
- • Personal Identification data: such as your date of birth, gender, employment status, immigration status, civil/marital status, photograph, and national origin.
- • Personality profile: such as your executive competencies, intellectual ability, personality, behaviour, and other character traits.
- • We may also collect sensitive information, such as information related to your physical or mental health, race or ethnic origin, religious beliefs and details of any criminal convictions. We only collect sensitive personal data from you, and further process this data, where it is appropriate to do so and where you have given your explicit consent.
- • Other information: any other relevant information you may choose to share with us.
In addition to what has been outlined above, we use Candidate data for the following purposes:
- • Data Analysis – to understand the reach of and improve our services
- • Marketing initiatives – in accordance to your marketing preferences, sending you information concerning opportunities, reports, research, general information that we believe you will find interesting.
As a Client of Lucena, we need to collect and use personal information about you or individuals at your organisation in the course of providing our services to your organisation. This information typically includes:
- • Contact Details: such as your name, email address and telephone number.
- • Job Title: including your role responsibilities.
- • information contained in your communication with us and other such information that we would naturally come into contact with while liaising with you regarding your search requirements and which you have chosen to tell us.
- • We will also keep a record of our contact with you in the usual course of our business and in order to manage our relationship with you.
In addition to what has been outlined above, we use Client data for the following purposes:
- • Relationship Management: To manage our relationship with you and your organisation.
- • Business Purposes: Data Analysis to better understand the use and effectiveness of our services.
- • Marketing Initiatives: in accordance to your marketing preferences, sending you information concerning opportunities, reports, research, general information that we believe you will find interesting.
In the course of the search process, we may ask a Candidate for the contact details of a Referee, so that we can contact them to obtain a reference. We process Referee contact details, such as your name, email address and telephone number. We may also process certain professional details such as your job title, occupation, academic and professional qualifications, and employment history, and your connection to the candidate.
We may process any further information you chose to give us as referee of the candidate, including your relationships to, experience with, and opinions about the candidate.
We may also use your personal information to contact you in relation to any of our Services that we think may be of interest to you.
We collect and process the personal information of any individual or Source who helps to identify and provide market intelligence about a potential Candidate. This information will typically include your contact details, certain professional details such as your job title, occupation, educational and employment history as well as information about your connection to the Candidate.
We may also use your personal information to contact you in relation to any of our Services that we think may be of interest to you.
We process limited personal information of our Suppliers for the purpose of contacting you regarding your services and managing our relationship with you. Such personal information will typically include your name and contact details, and a record of our contact with you.
We may also use personal information collected to help us where it is necessary to fulfil legal requirements or to establish or defend relevant legal claims.
FROM WHERE DO WE COLLECT YOUR PERSONAL DATA?
Information You Provide to Us: You may provide us with personal information when you speak to a search consultant, submit an Résumé, or communicate with us in any way in connection with our search services. You are not obligated to provide Lucena Search any information therefore, we will consider any information we collect directly from you as having been provided voluntarily.
Information Collected From Third Parties / Publically Available Sources: We may collect any of the above personal information from third parties and publicly available sources, including:
- (i) an agent or third party acting on your behalf;
- (ii) publicly available third party sources such as LinkedIn, company websites, press releases, public databases and news reports;
- (iii) Sources;
- (iv) Referees;
- (v) our Clients;
When we obtain information about you from third party providers or suppliers, we take the necessary steps steps to ensure that these third parties are legally permitted to disclose such information to us.
INFORMATION COLLECTED FROM VISITORS TO OUR WEBSITE
- • Your broad geographic location;
- • To identify individual clients behind a shared IP address and apply security settings on a per-client basis.
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OUR LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
The legal basis on which we process your Personal Information will vary depending on the data and the context in which we acquire this. The reason will usually be for our legitimate interests including but not limited to i) the provision of our service to you, ii) the ability to assess your suitability for potential roles or iii) the suitability of someone for whom you are a nominated referee. This applies only where your own data protection interests or fundamental rights and freedoms do not override our legitimate interests.
Where so required by law, we will collect personal information only where we have your explicit consent to do so.
In addition to the specific purposes for which we may process your personal data set out in this Section, we may where necessary, process the Personal Information identified for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, or in order to protect your vital interests or the vital interests of another natural person.
At times, we may also use your personal data for diversity monitoring, marketing and profiling. Where appropriate and practicable to do so, we will anonymise this data and/ or seek your consent before undertaking some of these activities.
SHARING YOUR PERSONAL INFORMATION WITH OTHERS
For the purposes described in this Notice, we may at times disclose your information to various third parties as follows:
- - Candidate data may be shared with Clients for the purposes described in this Notice and with Referees and Sources with whom we communicate in the process of providing services to our Clients;
- - Source and Referee data may be shared with Clients and Candidates where this is appropriate;
- - Client data may be shared with Candidates, Referees and Sources where this is appropriate;
- - We may share your data with third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors, administrators, accountants, insurers, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
- - We may share your data with Marketing technology platforms and suppliers;
- - We may use third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
- - In the event of the sale or merge of the business Lucena Executive Search, the personal data of our customers will be one of the transferred assets;
- - We may share your information with any other organisation or individual with your consent.
In addition to the specific disclosures of personal information set out in this Section, we may disclose your personal information 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. We may also disclose your personal information where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
We may at times transfer your Personal Information to clients and partners internationally, both within the EEA and to countries outside of the EEA.
We will only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data or where you have consented to this transfer of data.
Our customer and candidate relationship management platform and accounting software are based in the US at this time. The European Commission has made an “adequacy decision” with respect to the data protection laws of the US. Transfers to the US will be protected by appropriate safeguards, namely the use of the EU-US Privacy Shield approved by the European Commission, a copy of which can be obtained from https://www.privacyshield.gov/.
RETAINING AND DELETING YOUR PERSONAL INFORMATION
We will retain your personal information as follows:
- For as long as we have a continued legitimate business need to do so, such as managing our relationship with you and managing our operations;
- For as long as someone could bring a claim against us; and/or where such retention is necessary for compliance with a legal obligation to which we are subject
- Retention periods in line with legal and regulatory requirements or guidance.
Where we no longer have a legitimate business need to retain your Personal Information, we will either anonymise or delete this data at regular intervals in line with legal and regulatory requirements or guidance.
SECURITY OF YOUR PERSONAL INFORMATION
We will take appropriate technical and organisational precautions to secure your Personal Information and to prevent its loss, misuse or alteration.
We will store all your Personal Information on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the Internet is inherently insecure, and we cannot guarantee the security of information sent over the Internet.
AMENDMENTS TO THIS NOTICE
We may update this Notice from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this Notice.
We may notify you of significant changes to this Notice by email.
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
In this Section, we have summarised the rights that you have under data protection law. Some of the rights are 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.
Your principal rights under data protection law are:
- i) the right to access; 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.
- ii) the right to rectification; 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.
- iii) the right to erasure; In some circumstances you have the right to the erasure of your personal data without undue delay.
- iv) the right to restrict processing; In some circumstances you have the right to restrict the processing of your personal data.
- v) the right to object to processing; 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 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.
- vi) the right to data portability; In some circumstances, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format.
- vii) the right to complain to a supervisory authority; 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.
- viii) the right to withdraw consent; 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.
You may exercise any of your rights in relation to your personal information by written notice to us or by other contact methods as specified in this policy. We will respond as soon as we can, and will do so within 28 days.
This website is owned and operated by Lucena Executive Search Ltd. We are registered in England and Wales under registration number 09228691 and our registered office is at 27 Mortimer Street, London, W1T 3BL.
post, to the postal address given above;
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DATA PROTECTION REGISTRATION
Lucena Executive Search Ltd are registered as a data controller with the UK Information Commissioner’s Office.