Who are we?
HorrexCole Ltd, registered address Suite C2, Horsted Keynes Business Park, Cinder Hill Lane, Horsted Keynes, Haywards Heath, England, RH17 7BA. We are Specialist in Executive Search and Leadership hires across a range of organisations to include top FTSE and fast growing SME’s.
What does this policy cover?
We at HorrexCole 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 recruitment. This information includes CV’s, identification documents, educational records, work history, employment and references if provided.
We may also collect sensitive personal data about you, in the form of biometrics, race, ethnic origin, religion, trade union membership and health. We only collect sensitive personal data from you, and further process this data, where you have given your explicit consent.
For suppliers we engage, we may need to collect contact information or financial details for the purpose of managing our relationship or paying you.
Where do we collect personal data about you from?
You may supply us with personal information by filling in a form on our website. This includes information you provide when you submit a contact form or submit a form on any of our social media channels or via email. The information you give us may include your name, email address, telephone number and company name.
The following are the different sources we may collect personal 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. Associates/Freelancers/Contractors acting as a Limited Company, outsourced recruitment suppliers
- Through publicly available sources. We use the following public sources:
- Job Boards
- World Wide Web
- 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.
Information our website automatically collects about you.
With regards to each of your visits to our website, we may automatically collect information including the following.
- Technical information, including truncated and anonymised version of your Internet Protocol (IP) address, browser type and version, operating system and platform;
- Information about your visit, including what pages you visit, how long you are on the site, how you got to the site (including date and time); page response times, length of visit, what you click on, documents downloaded and download errors.
Where we collect your information through publicly available sources as set out above, we may do this with the aid of resources such as external research businesses/talent mapping associates. These suppliers are given parameters on the requirements of a role and search through publicly available sources to find such candidates. These suppliers are designed to only output information on candidates that meet the search criteria. The parameters of this supplier are restricted to only searching for candidate information from public sites where there is a reasonable expectation that such information may be collected and further processed by job recruiters for the purpose of sourcing candidates for different job roles.
After your details have been collected, if necessary to carry out our services your details will be stored on our central ATS (Invenias by Bullhorn) or stored securely in a cloud file and will be retained in line with our retention policy.
How do we use your personal data?
We use the information in the following ways:
Information you supply to us. We will use this information:
- to provide you with information and/or services that you request from us;
- Legitimate interest; we may use and process your personal information where necessary for us to carry out activities for which it is in our legitimate interest as a business to do so.
- Contractual; We may process your information where it is necessary to perform a contract with you or your company.
Information we automatically collect about you. We will use this information:
- to administer our site including troubleshooting and statistical purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- security and debugging as part of our efforts to keep our site safe and secure.
This information is collected anonymously and is not linked to information that identifies you as an individual. We use Google Analytics to track this information. Find out how Google uses your data at: https://support.google.com/analytics/answer/6004245
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. If you 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 for submission to our client.
Where you have provided your consent, we may use and process your personal information for marketing purposes:
- to contact you from time to time about our services, events, promotions or information of which we think may be of interest to you.
You can withdraw your consent at any time by contacting us at firstname.lastname@example.org
How long do we keep your personal data for?
We keep your information in accordance as follows:
Stored Candidate data: 2 Years from last contact
Placed Candidates: 6 Years from placement.
Client contact details: 2 Years from last contact.
Details of our retention policy can be provided on request.
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.
Email / Storage: Google LLC (for Google Drive) (Cloud Storage)
Location: US (EU-US Privacy Shield certified)
Email / Storage: Microsoft. View Privacy here.
To comply with legal requests:
On occasion, we may be required to liaise with various regulators, HMRC and law enforcement agencies in a number of different countries, whether as a result of law, a court order, or another legal process. In some cases we may have to share your information where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands.
What legal basis do we have for using your information?
For prospective candidates, interim managers, 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 or suppliers, 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.
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.
INTERNATIONAL DATA TRANSFERS
Our servers are hosted by Ionos and the information that we collect directly from you will be stored in their servers. We may also transfer your personal data to our third party service providers, many of whom may be located outside of the EU, operate from multiple locations including non-EU based operations or engage sub-processors located outside the EU.
There are agreements in place to ensure that any international transfers of personal data to our affiliates or third party service providers have appropriate safeguards that meet the requirements of EU data protection laws.
Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and approved by the European Commission, such as the European Commission’s standard contractual clauses. Alternatively, where personal data is transferred to the US, many of those US third party service providers are certified under the EU-US Privacy Shield framework approved by the European Commission.
To find out more about the standard contractual clauses, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
To find out more about the EU-US Privacy Shield certification, please visit: https://www.privacyshield.gov/Program-Overview
What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
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 us at email@example.com.
Changes to this Policy