Summit Search and Selection Ltd is committed to protecting your privacy and security. This notice explains how and why we use your personal data, to ensure you remain informed and in control of your information.
We will never sell your personal data and will only ever share it with organisations we work with where necessary and if its privacy and security are guaranteed.
Any questions you have in relation to this notice or how we use your personal data should be addressed to our Data Protection Officer using the details below:
Data Protection Officer
Summit Search and Selection Ltd
29 Farm Street
Your personal data (i.e. any information which identifies you, or which can be identified as relating to you personally) will be collected and used by Summit Search and Selection Ltd, a company registered in England and Wales with company registration number 04370431, whose registered office address is 4 Market Square, Amersham, Buckinghamshire HP7 0DQ.
For the purposes of data protection law, Summit Search and Selection will be the data controller and will be referred to as “we”, “us”, “our” from now on within this privacy notice.
This Privacy Notice Is Applicable To:
Candidates – potential candidates for any type of job or engagement through us and whose personal data is collected in the course of our services;
Referees – referees of Candidates whose personal data is collected in the course of our research of a Candidate; and/or
Corporate Staff – individuals who work for, or are engaged by, our customers, clients or suppliers whose personal data is collected in the course of our work with them.
We refer to the above groups of individuals collectively as “you” unless the context dictates otherwise.
This privacy notice replaces any privacy notice that we have previously issued and was last updated in February 2019.
Any notices or statements relating to data, data protection, fair processing and/or privacy that we may issue at the time of collecting personal data about you will supplement this privacy notice. They are not intended to override it.
We may change this privacy notice from time to time to reflect changes in the law and/or our personal data handling activities and data protection practices.
We encourage you to check this privacy notice for changes whenever you visit our website, as we may not always notify you of the changes.
It is important that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes during your relationship with us.
What Personal Data We Collect
Identity Data, which may include your title, first name, last name, maiden name, date of birth, gender, photograph, national insurance number (or equivalent in your country), nationality and other information relating to residency and citizenship which may be required to establish a right to work in a given country, marital status and number of dependents;
Contact Data, which may include your billing address, delivery address, email address and telephone numbers, emergency contact details and contact details history;
Historical Data, which may include educational history and credentials, employment history, skills and qualifications;
Employment-related Data, which may include your current remuneration, pension and benefits, what role you are looking for, what work-related areas interest you, third party references (if taken) and interview and assessment feedback created either ourselves or by our client following an interview or assessment;
Financial Data, which includes your bank sort code and account number and tax-related information;
Profile Data, which includes your interests and preferences and other insights or determinants that we have gained from our analysis and research of you;
Marketing Data, which includes your preferences in receiving emails marketing from our third parties and from us and your communication preferences.
Other Data – The above list of personal data is not exhaustive. You, your referees or third-party sources may tell us extra information that we have not listed above.
Special Category – We do not collect any Special Categories of Personal Data, such as religious beliefs, sexual orientation, political opinions, trade union membership, health and genetic information or biometric data about you.
We do not intentionally collect personal data relating to children.
Where We Source Your Personal Data from and How
- We generally collect your personal data directly from you. For example, we collect all of your personal data when you:
- Deal with us in person, by telephone, interview, letter, fax, email or via our website;
Submit any other information to us, such as a CV;
We also use the following channels to collect your personal data:
- Third parties; such as referee details from a candidate
- Publicly available sources – we may receive personal data about you from public sources, such as:
- social media sites, such as LinkedIn, Twitter and Facebook;
- publications, such as magazines;
- events that you attend; and
- qualification and membership lists of professional bodies.
What We Do with Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
We believe it is reasonable to expect that if you have posted your professional CV information on professional networking sites and other publicly available sources, you are happy for us to collect and otherwise use your personal data to provide our services, share that information with prospective employers and assess your suitability against our assignments.
We also believe that you will expect us to have an ongoing relationship over a number of years and we will continue to hold your data providing that we retain reasonable periodic contact with you or until you inform us otherwise. We need to do these things so that we can function as a profit-making business, and to be effective and help organisations acquire the right talent.
Sharing Your Personal Data
We will never sell or share your Personal Information to, or with, other unrelated companies for the purposes of direct marketing.
When necessary; we may share your personal information with:
- Our service providers who support us with providing services;
- Our clients;
- Tax, government and/or regulatory authorities;
- Prosecuting authorities and courts, and/or other relevant third parties connected with legal proceedings or claims;
- Fraud prevention and/or law enforcement agencies;
- Third parties when we sell any business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets; and
- Third parties where we are required to do so by law.
The recipients set out above may be based in the European Economic Area (EEA) or in countries outside the EEA.
We only allow our service providers to handle your personal data if we are satisfied, they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
Transfers of Your Personal Data Outside the EEA
Your personal data can be transferred outside of the EEA from time to time to trusted service providers and other third parties when necessary.
When we do this; we require third parties to keep your personal data confidential and secure. We ensure that suitable protection is maintained at all times by ensuring that appropriate safeguards are in place.
Where we are required by law to disclose, we may not always have control over the terms under which we are required to share your personal data. We will make sure that any disclosure is lawful.
Retaining Your Personal Information
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will usually continue to process your personal data in the usual manner for up to 5 years from the last meaningful contact we had with you (or such longer period which we believe in good faith circumstances and the law allows for legitimate interest to continue). Meaningful contact may include a consultant contacting you directly by phone or you may receive an email from us reminding you that we hold your personal information and asking you to let us know if you are no longer interested in remaining on our books.
We keep identification information and information relating to placements, records of any payments, tax information for 7 years from the end of the last transaction relating to you. We hold this information in case there is a legal claim or tax investigation.
Protecting Your Personal Information
We always maintain the security and protection of any information we hold by putting in place administrative, technical and physical measures on our systems and internally which are designed to guard against and minimise the risk of loss, misuse or unauthorised processing or disclosure of the personal information that it holds. We place similar obligations on our service providers and undertake robust risk assessments on their security measures.
We do not engage in any Profiling activities with your personal data
Automated Decision Making
We do not use any automated processes to make decisions about you which produce legal or significant effects concerning you.
Storing Your Personal Information
Where we store information
Our operations are based in the UK and we store our data within the European Union. Some organisations which provide services to us may transfer personal data outside of the EEA, but we’ll only allow them to do so if your data is adequately protected or with your permission.
For example, some of our systems use Microsoft products. As a US company, it may be that using their products result in personal data being transferred to or accessible from the US. However, we’ll allow this as we are certain personal data will still be adequately protected (as Microsoft is certified under the USA’s Privacy Shield scheme).
How long we store information
We will only use and store information for so long as it is required for the purposes it was collected for. How long information will be stored for depends on the information in question and what it is being used for. For example, if you ask us not to send you marketing emails for example about opportunities that we feel may be of interest to you, we will stop storing your emails for these marketing purposes (though we’ll keep a record of your preference not to be emailed).
We continually review what information we hold and delete what is no longer required.
Making A Data Protection Complaint
If you have any concerns about the use of your personal data, or the way we handle your requests relating to your rights, you can raise a complaint directly with us by contacting our Data Protection Officer using the details below:
Data Protection Officer
Summit Search and Selection Ltd
29 Farm Street
By email: firstname.lastname@example.org
If you are not satisfied with the way we handle your complaint, you are entitled to raise a complaint directly with the UK Information Commissioner’s Office via the details available on their website: www.ico.org.uk.
For alternate EU Data Protection Authority contacts please see further information on the following link National Data Protection Authorities.
Your Data Subject Rights and How to Exercise Them
You have certain rights relating to the personal information we hold about you which are outlined below, they may be subject to various exceptions and limitations.
You have rights to:
- Request access to the information we hold about you (Data Access Request)
You may request access to a copy of the personal information we hold about you.
We can refuse to provide information where to do so may reveal another person’s personal data or would otherwise negatively impact another person’s rights.
- Object to processing (Right to Object)
You may object to us undertaking automated processes, or fully automating decision making, using your personal data except where used to detect, prevent and investigate fraud and other financial crimes.
You may also object to us using your personal data for direct marketing purposes. This includes any profiling we perform as part of our direct marketing activities. Once we receive and have processed your objection, we will stop using your personal data for these purposes.
- Request a copy of your data (Data Portability)
Where you gave us the information directly and it was processed electronically, you can request the data we hold on you in a commonly used machine-readable format.
- Request that your data is deleted (Right to be Forgotten)
You can ask us to delete the personal information we hold about you when it is no longer required for a legitimate business need, legal or regulatory obligations or for the purposes it was collected for.
- Amend or correct your information (Right to Rectification)
If you believe that the personal information that we hold about you is inaccurate, incorrect or incomplete, please contact us as soon as possible so we can update it.
- Restrict the processing of your information (Right to Restrict)
You may ask us to restrict our processing of your data whilst we resolve any complaints you have about the way your data is used, require it for a legal claim or if you think our processing is unlawful but you do not want us to delete your data.
- Rights in relation to consent (Right to Withdraw)
At any time, you may withdraw the consent you granted for your personal information to be used for direct marketing.
When you withdraw your consent, it will not affect the lawfulness of any past activities we have undertaken based on the previous consent.
You can exercise these rights at any time by contacting our Data Protection Officer using the contact details found in this notice. Please note we will need to validate your identity before we can look into your request.