WHO WE ARE
We provide executive search services to clients looking to recruit for their businesses. We also provide talent mapping services to clients in addition to leadership consulting services through Pantheon Leadership which is part of Per Ardua Associates.
WHAT DOES THIS POLICY COVER?
This Privacy Policy explains our use of personal data processed through the website, if you choose to contact us and our use of business contact details. It also explains how we use candidate personal data and the personal data of our clients.
We at Per Ardua Associates 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
• explains how we may contact you and how you can contact us
WHAT PERSONAL DATA DO WE COLLECT AND WHY DO WE USE IT?
The table below explains who we collect personal data about, what that personal data is and the purpose we process it for.
The last column sets out the ‘lawful basis’ we rely on for processing that personal data which is a requirement of data protection rules. Essentially, companies may only process personal data if they can identify a lawful basis from a list set out in the legislation.
Individual | Personal Data | Source and Purpose | Lawful Basis for Processing |
Candidates | CVs, educational records, work history, employment record and references, correspondence and other personal data provided by you as part of the recruitment or engagement process. We rarely process special category information such as racial, disability, or health information where you have made this available to us. | We mainly collect this information directly from you during the management of executive search. Sometimes we collect information from third parties such as; by word of mouth, including from a friend, a colleague or an employer, past or present; from potential employers giving feedback to us during the executive search process; or from a person giving a reference. We do use some publicly available sources to find information about potential clients and candidates. | The processing is necessary for our legitimate interests of assessing suitability for potential roles, to find potential candidates. If you choose to give us special category data we obtain your express consent to process that. |
References/ referees | Contact details and correspondence. | Reference contact details may be given to us by candidates as part of a recruitment process. Other personal data about referees is given to us by you directly. | Our legitimate interests as a business in obtaining references on candidates. |
Individuals who contact us with general queries
| Contact details provided and correspondence. | This information is given to us by you. It is used to respond to the query and keep a record of it. | Our legitimate interests as a business in responding to and keeping a record of correspondence. |
Clients and potential clients | Contact details provided and correspondence. Contracts. | This information is given to us by you or from publicly available information (for example on your website). It is used for us to fulfil contracts and engage in business discussions. | Our legitimate interests as a business in responding to and keeping a record of correspondence. Some information is also necessary for us to perform our contract – for example certain contact details. |
Coaching clients or recipients of coaching services from of Pantheon Services (i.e. where we are providing executive or staff coaching services either directly to you or via your employer.) | Contact details, correspondence, assessments, information provided, analysis and recommendations and opinions. This may include psychometric assessment data where this forms part of the coaching process with you. Special category information such as health, disability or ethnicity or racial information is only processed if provided by you. | This information is given to us by you. Occasionally we undertake feedback sessions as part of coaching which may involve the provision of information about you from other people known to or nominated by you. We use the information to provide our coaching services to you or to your employer. | Our legitimate interests as a business in providing coaching services. Some information may also be necessary specifically for us to perform the contract where it is with you directly. We only process special category data with your express consent. |
Suppliers and contractors | Contact details and provided correspondence. | This information is given to us by you or from publicly available information. It is used for us to fulfil contracts and engage in business discussions. | Our legitimate interests as a business in responding to and keeping a record of correspondence. Some information is also necessary for us to perform our contract – for example certain contact details. |
Website visitors | Information from cookies. For more details see our Cookie Notice. | This information is collected via the cookies when you use our website. It is used to generate reports that are used to improve our online offering. We use Google analytics to achieve this. Google’s privacy policy is available here. | We only install non-essential cookies with your consent. For more details see our Cookie Notice. |
Where we have indicated in the table above that we rely on legitimate interests for processing of personal data, we carry out a ‘balancing’ test to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing.
Where we collect candidate information through publicly available sources as set out above. These programs are given parameters on the requirements of a role and search through publicly available sources to find such candidates. These programs are designed to only output information on candidates that meet the search criteria. The parameters of this program are restricted to only searching for Name and Job role 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.
HOW LONG DO WE KEEP YOUR DATA FOR?
We keep your information only for as long as is necessary for the relevant purpose.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
Data may be shared in the following circumstances:
Where you are a candidate:
- we share your personal data with the client who has a search for which you are being considered, to determine with the client whether you are a good fit for the available position. We work with a broad range of clients within the financial services sector globally;
- we may also conduct checks in order to verify information you have provided and where we do this we share your information with a third party background checks agency.
Where you are a recipient of Pantheon Services coaching, we share your personal data with:
- consultants who act as coaches on our behalf;
- clients to whom we report at the end of the coaching process. (We will not include in our report to clients personal data that you have not consented to share);
- Advanced People Strategies Limited which provides and hosts the Hogan 360 software app we use for assessment of executives.
• With professional advisors;
• In the event of a sale of the company or its assets;
• With suppliers but only subject to robust contractual protections;
• Other companies in our group.
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, we may not be able to respond to your query or consider your application or request or match you with available role opportunities or to provide the relevant services to you.
DO WE MAKE AUTOMATED DECISIONS CONCERNING YOU?
We do not carry out this type of processing activity.
DO WE USE COOKIES TO COLLECT PERSONAL DATA ON YOU?
To provide better service to you on our websites, we use cookies to collect your personal data when you browse. See our cookie policy here for more details.
DO WE TRANSFER YOUR DATA OUTSIDE THE EEA?
We may sometimes transfer your personal data to countries outside the UK and European Economic Area, for example, to our group companies, or if we are either using a supplier or working with a client based elsewhere. You can find the list of European member states by clicking on the following link: https://europa.eu/european-union/about-eu/countries/member-countries_en. The privacy laws in countries outside the UK and European Economic Area may be different from those in your home country.
At present, we transfer personal data to the following countries outside of the UK and European Economic Area: United Arab Emirates, Australia, Bermuda, Switzerland and USA.
For Pantheon Services, some of our consultants who process your personal data are located outside the UK including Abu Dhabi and Singapore.
Where we transfer data to a country that has not been deemed to provide adequate data protection standards, we always have security measures and approved model clauses or other adequate safeguards in place to protect your personal data. Please contact us if you would like more details about our safeguards for data transfers.
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. In the UK this is the Information Commissioner.
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 in some circumstances.
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.
| Rights | 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 Privacy Policy. If you have any additional questions, for example regarding transfers and locations of data or our legitimate interests basis, do please get in touch. |
| 2. The right of access | You have the right to obtain access to your information (if we are processing it), and certain other information (similar to that provided in this Privacy Policy). |
| 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 is no compelling reason for us to keep using it. This is not a general right, 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. This is not a normal scenario for companies of our nature but if you have any questions you can contact us. |
| 7. The right to object to processing | You have the right to object to certain types of processing, including processing for direct marketing or where we are relying on our legitimate interests for processing (e.g. if you no longer want to be contacted with potential role 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. |
UPDATING THIS PRIVACY POLICY
This Privacy Policy may be updated periodically to reflect changes in personal data protection legislation and best practices. When we make changes to this Privacy Policy, we will change the “last updated” date above and will notify you of any significant changes to this Privacy Policy.
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 here:
Per Ardua Associates Ltd
Level 14, Tower 42
25 Old Broad Street
London
EC2N 1HQ
If you are based in the EU, you also have the option to contact our EU Representative:
Datarologie, 2nd Floor, Avenue Marnix 23, 1000 Bruxelles, Belgium
Per-Ardua.EURep@datarologie.com
