PRIVACY POLICY | Lothbury Partnership

Who are we?

The Lothbury Partnership, 41 Lothbury, London, EC2R 7HG, T: +44 (0)20 7466 6044

We are an executive search partnership providing specialist advice to investment banking firms across the UK and EMEA with regard to their hiring needs.

What personal data do we collect about you?

We collect a variety of personal data in order to provide our advisory services. For candidates, this typically includes employment history, educational qualifications, nationality, languages and any other relevant skills as well as contact information. It may also include compensation details, a record of our contact history with you and comments, views or references from third parties. We advise you not to provide information which may be deemed sensitive on your CV as we will retain any documents that you have provided. For clients and potential clients, referees and sources data typically includes contact details, company information and role. In addition to information provided by you, we may gather information from LinkedIn, Google, Company websites, press and periodicals and other publicly available sources. Selectively, we may hold sensitive personal data if relevant to a specific search and subject to your consent.

How do we use your personal data?

We use your personal data to assess your suitability for specific executive searches that we are engaged by our clients to run. We may also use your data to contact you as a source or referee or as a potential client at times. By choosing to provide us with your personal information you indicate your willingness to share and have your information stored by us and to be considered, when appropriate, for one of our confidential executive searches. Summary biographical date may be shared with a client in the context of a particular search, for example to identify the most highly qualified and talented individuals or to illustrate a typical profile within the individual search parameters. No representation is made about your interest or availability to contemplate such a role at this stage. Before presenting further details or indicating any potential interest you might have, we would make direct contact with you. Your personal information may also be used anonymously and in the aggregate in order to put together industry, marketing and employment statistics. Used in this matter, your personal information becomes non-identifying. For clients, we use your data to provide the services to your organisation and to manage our relationship with you and your organisation.

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 take into account 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 issued by relevant data protection authorities.

Otherwise, we securely erase your information where we no longer require your information for the purposes collected.

Who do we share your personal data with?

We share your personal data with the following types of third parties for the purposes described in this policy:

In the case of candidates, referees and sources, we may share your information with clients who will need to process your information for the purposes we have described in this policy.

We may share your information with any competent law enforcement body, regulatory or government agency, court or other third party where we believe disclosure is necessary as a matter of applicable law or regulation; to exercise, establish or defend our legal rights; or to protect your vital interests or those of any other person.

We may share your information with third party service providers eg technical support providers, outsourced IT and document storage providers.

We may share information with any other person with your consent.

We may also conduct checks on you to verify the information you have provided and where we do this we share your information with our client but we will not share it with any other party.

Data is shared internally within the Lothbury Partnership amongst key staff who may process that data on behalf of and with the authority of the data controller.

We do not sell your information to third parties or use the information for purposes that are incompatible with those set forth in this policy.

What legal basis do we have for using your information?

For prospective candidates, contractors, 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. 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 interviewed and submitted 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, 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 you withdraw your consent for the processing of your personal data, we may not be able to consider you for future executive searches.

Do we make automated decisions concerning you?

We do not make automated decisions about you during the assessment stage of the search process. We do put candidates through our internal, structured screening process to assess whether each candidate meets the specific criteria for a particular position. This process is judgement and experience based, it is not automated.

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.

At present we transfer personal data to the following countries outside the EEA:

The United States of America

Canada

Switzerland

Do we use cookies to collect personal data about you?

Our Cookies do not collect personal information about you.

Data security and integrity

The data is stored in a secure and highly confidential database accessible only by Lothbury Partnership employees.

We use our best efforts to ensure that data is accurate, complete, current and reliable for its intended use. We use appropriate technical and organisational measures and safeguards to help protect your personal data from unauthorised access, misuse, alteration or loss.

What rights do you have in relation to the data we hold on you?

You have the right to obtain access to your personal data; to have it updated or corrected if it is inaccurate or incomplete; to request that we restrict its processing or remove your data entirely from our system. When asked to remove a record from our database, Lothbury Partnership will retain minimal information to ensure we do not contact you or collect such information again or to keep a record of any information disclosed to our clients.

If you do not wish us to hold any data on your or would prefer that we do not contact you for any reason, please email jo.mills@lothburypartnership.com.

How will we contact you?

We may contact you by phone, email or business networking internet sites. If you prefer a particular contact means over another, please 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, please address your communication to our Data Protection Officer at:

The Lothbury Partnership, 41 Lothbury, London, EC2R 7HG, T: +44 (0)20 7466 6044

E: jo.mills@lothburypartnership.com

E: emma.child@lothburypartnership.com

Changes to Privacy Policy

Lothbury Partnership reserves the right to modify or amend the Privacy Policy at any time and for any reason, as permitted by applicable law. If there are material changes to the Privacy Policy, we will post those changes here.

Last updated 25^th May 2018