This policy explains how we process personal data within our international business delivering search, selection, consulting and assessment services.
Who we are
We are Greenings International. Further information about our company can be found on our website by clicking here.
We are committed to keeping your information secure and managing it in accordance with our legal responsibilities, under the privacy and data protection laws applicable wherever we operate in the world, as well as the General Data Protection Regulation (Regulation (EC) 2016/679 (“GDPR”) in the European Union (“EU”).
This policy was last updated in May 2018. Please review this policy periodically for any changes.
Who this policy applies to
We provide executive search, selection, sourcing and assessment services to a range of clients around the world. Details of our services can be found on our website by following the link above. This policy applies to you if you are
- A candidate for one of our clients
- A client
- A source or a referee in respect of a candidate for one of our clients
For the purposes of this policy:
Candidate means an individual who is a candidate, applicant, potential candidate, employee of a client who is being considered for a role as part of our normal business process;
Client means any business, firm, company or organisation that contracts us to perform our services on their behalf;
A referee is a person who provides a personal or work reference in respect of a candidate;
A source is a person who provides us with information or intelligence about a candidate or a potential candidate.
Our clients require us to identify the best individuals to fill roles within their organisations. To do this we need to research systems, online databases, social media and other information sources, and talk to many individuals. As well as our clients, these individuals will include referees and sources to help inform our decision-making process.
The nature of our work means we are required to process personal data quickly, confidentially and often without reference to the data subject. Accordingly, we process such data in accordance with the Data Protection Laws, regularly using our legitimate interest where it is not possible or feasible to speak directly with the data subject. Beyond this, we will seek consent in the circumstances explained later in this policy document.
We collect information from candidates directly when you provide your CV or other information about you in any form by e-mail, post, uploading it to our website, or via any other means. We also collect information from you when you speak with an employee or consultant of Greenings International at any location in the world.
How we use your personal data
We use the personal data we collect from you for a number of purposes:
- Processing job applications, in partnership with our clients, on whose behalf we are instructed to help fill a job vacancy. This means that if you apply for or, following an approach by us agree to apply for a specific job, we may pass your details to the relevant client to proceed with the application. This may result in you may receiving further direct correspondence from them.
- Searching for relevant candidates for confidential recruitment assignments where our client may or may not be identified initially. This means that if we believe you are suitable for a specific role, we may pass your basic details on to the relevant client. If that client agrees that you might be suitable, we will then discuss this with you in more detail. You might be interviewed for the role by one of our consultants. If successful, you might be shortlisted for interview by our client. At this point, we will pass further details to the client and you may receive further direct correspondence from them.
- If allowable under applicable law, for equality monitoring purposes, to understand the diversity of our applicant pool. (In this event, the information is anonymised and aggregated).
- Improving the service we offer; for example, we may ask you to provide feedback on your experience of being a candidate with us.
- For marketing purposes to send you information on our services, events and so forth. Please note you may opt out from receipt of marketing materials at any time by writing to us.
We will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others or, have your permission to do so.
Please be aware that we are not responsible for the data processing activities of others, such as our clients.
We will use client data to perform our services for you and other legitimate business purposes such as marketing.
Source and Referee
We will use source and referee data to perform our services, in particular, to enable us to obtain your opinions on a candidate.
We may also use this information to enable us to market our services to you as a potential client. We may additionally invite you to become a candidate in respect of the provision of our services.
The type of personal data we collect and process
In all cases, we collect and process personal data about you, including your name, address, telephone number and email address.
If you proceed with a job application, or should we consult you about a role, you may be required to submit additional personal data. For example, date of birth, education, career history, curriculum vitae (CV) or resume which may contain: employment history, education, professional qualifications, memberships, details of papers written, references and referees, amongst other things.
When required to do so by our client as part of their employment process and with your explicit consent, we may also process any relevant psychometric assessments, psychological tests, or results from such assessments or tests.
From time to time, we may ask you to provide information relating to protected characteristics, such as your race or marital status. When this is the case, we do this for equal opportunity monitoring purposes, but only if permissible under local law. This information is always anonymised and aggregated.
We might also collect personal data from third-party databases and other public sources.
As well as basic contact information we will also collect information about your company, the role and other information provided to us by your organisation.
Source and Referee
As well as basic contact information we will also collect information regarding your credentials as a source, details of your relationship/knowledge of a candidate and your opinions of that individual. We may obtain this information directly from you or publicly available information.
What we do
Besides filling particular vacancies, we also process personal data when we conduct market intelligence exercises to map out particular business sectors or functions to help clients understand the available talent.
From time to time, we will seek your consent to process personal data in respect of certain specific and limited purposes. We will always do this before processing any sensitive personal data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sex life and sexual orientation, genetic and/or biometric data. We encourage you not to provide us with sensitive personal data unless it is specifically requested, and we have your consent.
In certain countries, we will not collect personal data from you unless you have specifically agreed to this. Your agreement might come via an electronic tick-box on our website or other electronic channels, or via other similar measures required by local privacy and data protection laws.
Your right to object and to have your data erased
You are not obliged to provide any personal data to us. However, please note that this may mean we will not be able to consider you in respect of any of our services.
You may withdraw any consent you have previously given, at any time. Also, you have the right to ask us to stop processing any personal data and to have it erased.
In these circumstances, we reserve the right to maintain basic personal data such as your name and address to ensure your personal data isn’t processed by us in the future.
Please note that no automated decisions are made on the basis of the information we collect.
From time to time, we may contact you with updates on our services, terms of business or simply to ensure that the data we hold is current, relevant and up to date.
If you have indicated you wish us to, we may also provide you with updates on events, developments or activities that Greenings International is undertaking or involved with. You may unsubscribe from these communications either through the unsubscribe button on the communication itself or via email.
If you agree to provide feedback, we may ask you to provide us with personal data, including your name, email address, and your views and opinions.
Providing information to others
To help us run this website, and to provide executive search services or assessment services in certain countries, we work closely with trusted partners with whom we need to share personal data. These partners include:
- Greenings Selection Limited
- Our clients
- Prospective clients, where we might need to demonstrate an understanding of a particular market and the individuals that work within it
Where we share information with such a third party, you will not be contacted by them, unless we have obtained your prior consent.
We may also provide information to third party service providers who process information on our behalf. This is to help run some of our internal business operations, including email distribution, IT services and customer services. As part of our agreements with them, these third parties are required to process such data securely and only in accordance with our instructions.
Your information may also be shared with organisations located elsewhere in the world. As their privacy laws may not match your home country’s standards, we’ll only make a transfer data if adequate levels of protection are in place to protect any information held in that country, or the local service provider complies with applicable privacy laws at all times.
Where required by law, we will take measures to ensure that personal data handled in other countries will receive at least the same level of protection as in your home country.
We may sometimes be required to disclose information about you to law enforcement bodies, agencies or third parties, under a legal requirement or court order. We will act responsibly and take account, where possible, of your interests when responding to these requests.
If you are concerned about these arrangements to disclose or share personal data with third parties, you should contact us and ask us not to process your personal data.
Keeping information secure
We invest significant resources to protect your personal data, from loss, misuse, unauthorised access, modification or disclosure. However, no system can be 100% secure, and so we cannot be held responsible for unauthorised or unintended access that is beyond our reasonable control.
Information about others
Keeping your records
We keep your personal data for as long as required to provide our services, and in accordance with legal, tax and accounting requirements. Where your personal data is no longer required, we will ensure it is disposed of in a secure manner. Where required by law, we will notify you when this has happened.
In some jurisdictions, you may have the right to request copies of your personal data held by us. If you think any of that data is inaccurate, you may also ask us to correct it. You may also have a right, in certain circumstances, to require us to stop processing your personal data. Also, you have the right to ask us to transfer your personal data to someone you nominate for your own purposes.
To get in touch with us about any of this, please email or write to us at the address below. Please note that we may request proof of identity. We will respond to your requests within the time frame that applies in the country concerned.
In certain circumstances, in countries where it is required or permitted by law, we might not be able to provide you with access to some of your personal data. Wherever possible, we will notify you of the reasons for this.
If you have a complaint about how we have handled your personal data, contact us using the details below, and we will investigate your complaint. Please use the same contact details to instruct us to cease processing your personal data.