This policy applies to all Jason Garrett Ltd.'s employees, candidates, clients, third party vendors and website users.
This policy describes the organization's objectives and policies regarding responding and handling of personal data.
Who are we?
Jason Garrett Limited, 60 Gresham Street, London, EC2V 7BB, Tel: +44 (0)20 3440 9646, firstname.lastname@example.org. We are a specialist fixed income search company based in the City of London providing executive search services and talent solutions to our investment banking and “buy side” clients seeking to recruit talent for their businesses.
What does this Policy cover?
We at Jason Garrett Limited Search 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.
Keeping your personal data secure
We have put in place appropriate organisational and technical measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
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, references, compensation & performance history and our contact history.
We only collect sensitive personal data from you, and further process this data, where you have given your explicit consent.
The personal information we collect from our clients and suppliers is very limited. We may collect contract details to ensure our relationship with you runs smoothly. Client and supplier data is processed by us under the lawful basis of contractual necessity.
Where do we collect personal data about you from?
The following are the different sources we may collect personal data about you from:
- Directly from you. This is information you provide when meeting with us or during interviews or meetings throughout any recruitment or search process.
- Through publicly available sources. We use the following public sources:
- Financial news media
- FCA website
- 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.
How and why we use your personal data?
We use your personal data to match your skills, experience and education with potential employers who are clients of Jason Garrett Ltd. We may initially collect basic information on you such as contact details, job role and experience and use this in the following manner;
- Creating or updating market mapping documents or monitors.
- identifying potential fit for a specific role or mandate we are working on with one of our clients.
- If we believe your profile suits the role we are working on we may add you to a short list and likely contact you regarding the role. If you are interested in the role we may seek to introduce you to the client for interviews. If you are chosen by the client and go through to the next stage(s) we may collect more information from you at the interview stages or at further meetings until placement i.e. performance and compensation history, identification documents, and any other information you tell us.
- When you approach us to help you with your career aspirations we may collect some of the above data to help us introduce you to suitable opportunities when they arise.
How long do we keep your personal data for?
We only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
When determining the relevant retention periods, we will consider factors including;
- Our contractual obligations and rights in relation to the information involved;
- Legal obligation(s) under applicable law to retain data for a certain period of time;
- Our legitimate interest where we have carried out a balancing test (see legal basis below);
- Statute of limitations under applicable law(s);
- (potential) disputes;
- If you have made a request to have your information deleted; and
- Guidelines issues by relevant data protection authorities.
Otherwise, we securely erase your information after seven years if we have had no communication with you (or the company we are working for or with) about any potential roles or general career update.
Who do we share your personal data with?
Relevant personal data may be shared with our investment banking and buy side clients when they are seeking to recruit profiles in fixed income that may match yours. We share your personal data to ascertain your potential fit for the available role. These clients may include hedge funds, alternative asset managers or institutional investors based in Europe or globally.
We may also conduct checks on the information you have provided with our network and personal contacts across fixed income.
What legal basis do we have for using your information?
For prospective candidates, referees and clients, our processing is necessary for our legitimate interests as a provider of executive search services to our clients and candidates. We need the information in to order to be able to assess suitability for potential roles and to find potential candidates and to contact clients and referees.
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. We keep a record of these balancing tests. You have a right to and can find out more about the information in these balancing tests by contacting us using the details below.
If you are shortlisted as a candidate, then this may involve the processing of more detailed personal data including sensitive data that you or others provide about you. In that case we always ask for your consent before undertaking such processing.
For clients, we may also rely on our processing being necessary to perform the following activities that range from general client coverage, search and to comply with any contractual terms agreed between ourselves.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If we do not have or you do not provide the necessary personal data, or withdraw your consent for the processing of your personal data, we may not be able to bring to your attention job opportunities that may match your profile.
Do we make automated decisions concerning you?
No, we do not carry out automated profiling.
Do we transfer your data outside the EEA?
To better match your employee profile with current opportunities we may transfer your personal data to clients and partners in countries outside the EEA. These countries privacy laws may be different from those in your home country. Where we transfer data to a country which has not been deemed to provide adequate data protection standards we always have security measures and approved model clauses in place to protect your personal data. To find out more about how we safeguard your information as related to transfers contact us on email@example.com.
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.
|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 Policy.|
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.|
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. Please advise us of your preferred means of contact if different from the above.
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, please contact here: Data Privacy - Jason Garrett Ltd, 60 Gresham Street, London EC2V 7BB, Tel: +44 (0)20 3440 9646, firstname.lastname@example.org.