PRIVACY AND COOKIES POLICY
Welcome to our global website www.greenwaycollins.com (our “Site”). Greenway Collins (“we”, “us” and “our”) is a unique global search firm, delivering exceptional talent and leadership, with offices in London. . We specialize in senior functional roles for major corporates, financial institutions and professional services firms, operating globally from our offices in London.
Greenway Collins Search Ltd
7-8 Stratford Place,
London W1C 1AY
Our commitment to diversity and inclusion, a transparent process and our collaborative culture sets us apart, ensuring every client gets the best of Greenway Collins’s collective energy wherever they are in the world.
This Policy deals with the protection of your rights under applicable data protection legislation, including without limitation the Data Protection Act 1998 and General Data Protection Regulation (‘GDPR’) (as applicable) and including where applicable the guidance and codes of practice issued by the Information Commissioner’s Office or any other relevant regulator.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We’ve set out what we do in enough detail to help you find the information you need at a glance, with the option of expanding on the links below if you want to find out more. If you still can’t find the information you need, you can email us at firstname.lastname@example.org or write to us at the above addresses.
WHAT IS PERSONAL DATA AND PROCESSING – DEFINITIONS
For the purposes of this policy “Personal Data” consists of any information that relates to you and/or information from which you can be identified, directly or indirectly. For example, information which identifies you may consist of your name, address, telephone number, employment history, salary information, education history, professional experience and resumé or an online identifier (e.g. cookie identifiers and your IP address). When we combine other information (i.e. information that does not, on its own, identify you) with Personal Data, we treat the combined information as Personal Data.
It is not our policy to seek any “Sensitive Personal Data” from you (or any other source) when providing our services, unless legally required to do so. Sensitive personal data includes data relating to race or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health, sexual life, or criminal record. We encourage you not to provide us with any sensitive information of this nature. If you do provide us with your sensitive personal data for any reason, by providing such information you indicate your willingness for it to be used in the ways described in this Policy or as described at the point where you choose to disclose such information.
“Processing” means any operation or set of operations performed upon Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. This Policy applies to Personal Data collected by us in connection with our services, whether offline or through our site, and will apply whether you access our site using a computer, mobile phone, tablet, TV, or other device.
“Site” means https://www.greenwaycollins.com/ and all web pages hosted at that domain.
PERSONAL DATA WE MAY COLLECT FROM YOU
Greenway Collins is an executive search firm providing search, due diligence and advisory services (our “Services”). We collect Personal Data from candidates for senior executive positions (as a “Candidate”) for the purposes of carrying out such services on behalf of our clients world-wide, where we have a legitimate interest or other legal basis for processing such information.
Personal data you give us directly
You may provide us with your Personal Data directly when you correspond with us by telephone, e-mail or otherwise. This includes Personal Data you provide when you submit a request via the ‘contact us’ page on our Site. The information you give us may include your name, address, e-mail address and telephone number, job title, company name, CV or other personal details that may be included in any enquiry you make.
Your career and other ways we may collect your Personal Data
In order to provide our services as a global search firm, we collect, process, use and retain Personal Data as part of the executive search process. We may get in touch with you to assess your professional experience or retrieve extra information which will be important to your qualification for a senior role. This might include your contact details, the information in your CV, compensation, referees, and details for background checks, for example employment or education history. It is our duty to keep your Personal Data up to date and we appreciate your assistance with this, by keeping us informed of developments in your career. We may also compile data from searches of your professional information publicly available via social media platforms such as LinkedIn, Google, Twitter, company websites, the press or other publications and data on your suitability for senior executive opportunities as part of our assessment of your professional profile. Any such relevant information will be deemed as “Candidate Personal Data” and processed alongside any Personal Data that you have submitted. You are of course free to choose which, if any, Candidate Personal Data you provide; however, generally the more information you make available to us (but please note it is not our policy to seek Sensitive Personal Data as set out above), the better we are able to assess you as a “Potential Candidate” in an executive search process for our clients.
HOW WE USE YOUR PERSONAL DATA
How we process information
Your Personal Data may be processed for the purpose of providing our Services as defined in this Policy, in some of the ways listed below with your consent:
We may collect process and retain your Personal Data on the terms set out in this Policy and in our Terms and Conditions agreed with you and share your Personal Data between our Greenway Collins offices on a confidential basis where required for the purpose of providing our Service for administrative, billing and other business purposes.
As a Potential Candidate we may include your Personal Data as part of an executive search process on behalf of our clients including to enable us to fulfil our obligations under any contract (such as our Terms and Conditions for executive search assignments). We may also evaluate your qualification for a role and verify your Candidate Personal Data for the search process and in order to manage our database.
Professional Career Advice
You may keep in touch with us so we may provide you with professional career advice. We may be in touch with you from time-to-time as a source of information about potential candidates for our clients. We may also keep you informed of possible executive positions and opportunities with our clients that suitably match your skills and experience and make strategic introductions to help you and our clients build networks for future opportunities.
We may also use Personal Data for the following:
- Analysis purposes – for assessment and analysis of our market, clients and services (including asking you for your opinions on services and carrying out client surveys);
De-identified data – to create anonymous, aggregated statistics about the use of our services, or other industry, marketing and employment statistics. This anonymized data may be shared with third parties;
- Service improvement – to develop and improve new and existing services, recommendations, advertisements and other communications and learn more about your preferences;
- Client support services – to provide client support services, or to deal with any other support queries you may have;
- Crime prevention – for the prevention or detection of fraud or crime;
- Security – to assist in keeping our Site safe and secure;
- Business purposes – for business monitoring and internal record keeping. We may use your Personal Data for our business purposes, such as audits, internal communication regarding candidates and clients, determining the effectiveness of our promotional activities, administering our services, maintaining and securing our infrastructure, and for procurement and financial transactions;
- Legal obligations – to comply with our legal obligations, arising under applicable law;
- Training – for staff training and quality assurance purposes, particularly in relation to our executive search consultants;
We will retain your Personal Data for the period necessary to fulfil the purposes for which it was collected as outlined in this Policy unless a longer retention period is required by law. Where you provide us with your Personal Data for the purposes of being considered for our executive search and other services, it is in Greenway Collins’s legitimate interest to retain such Personal Data, so we can notify you of and consider you for future opportunities which may be of interest to you. If you no longer wish us to hold your Personal Data on our system and for requests for access, or corrections, please email us at email@example.com. Please refer to the “ACCESSING YOUR PERSONAL DATA AND OTHER RIGHTS YOU HAVE” section of this Policy.
TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?
We may disclose your Personal Data to the following entities:
With discretion and confidentially we may disclose excerpts of your Candidate Personal Data where we are engaged to provide our services to a client, (as set out in this Policy) to such client for the purposes of our executive search assignments or our Services. We will only disclose what is necessary for the purpose and will seek to obtain your permission to disclose your Candidate Personal Data in greater detail and when putting you forward on an executive search.
Third Party referees
With discretion we may disclose excerpts of your Candidate Data to other organisations or individuals (e.g. former colleagues or other individuals within your industry) for reference or recommendation purposes or where we need to conduct other background checks as part of the executive search process. We will only disclose what is necessary for that purpose.
We use third party service providers to help us to administer certain activities and services on our behalf, such as IT services, management of our database servers and hosted software, CV verification, and background checks. We may share your Personal Data with such third party service providers solely for the purpose of enabling them to perform such services on our behalf and they will operate only in accordance with our instructions and will be subject to applicable Data Protection Legislation.
Third parties when required by law or to protect our services
We will disclose your Personal Data to comply with Data Protection Legislation and applicable laws or respond to valid legal process, including from law enforcement or other government agencies; to protect our clients and candidates (e.g. to prevent spam or attempts to defraud users of our services); to operate and maintain the security of our Services (e.g. to prevent or stop an attack on our systems or networks); or to protect the rights or property of Greenway Collins, including enforcing any terms or agreements governing the provision of our services
Other parties with your consent or at your direction
We may share Candidate Data about you with third parties when you consent to or request such sharing.
WHERE WE STORE YOUR PERSONAL DATA
Your Personal Data will be stored in our confidential encrypted database, accessible only by Greenway Collins or by third party service providers acting on our behalf. The Personal Data that we collect from you may be transferred to, processed, and stored at a destination outside the European Economic Area (“EEA”), including but not limited to our New York office in the United States of America or in any other country where Greenway Collins or its affiliates, subsidiaries or service providers maintain facilities. Your Personal Data may also be processed by staff operating outside the EEA who work for us (e.g. in our New York office) or for one of our suppliers. Such staff may be engaged in the provision of support services, among other things.
By using any of our services and/or submitting to us your Personal Data to us, you agree to the collection, transfer, storage and processing of your information outside of the EEA. We will take all reasonable steps necessary to ensure that your Personal Data is kept secure and treated in accordance with this Policy and the requirements of applicable law wherever the data is located. Where we transfer your Personal Data outside the EEA to other countries, we will ensure that appropriate transfer agreements and mechanisms (such as the EU Model Clauses which govern the transfer of Personal Data between our UK and New York offices) are in place to help ensure that our third party service providers provide an adequate level of protection to your Personal Data. We will only transfer your Personal Data outside the EEA in accordance with Data Protection Legislation and applicable laws or where you have given us your consent to do so.
WHAT DO WE DO TO KEEP YOUR PERSONAL DATA SECURE?
We use the appropriate physical and technical measures created to safeguard your Personal Data. Once we have received your Personal Data, we use strict procedures to prevent illegal processing and we have security features to try to prevent unauthorised access, including firewall, anti-virus software and encryption. Both physical and technical safeguarding measures are regularly reviewed and updated. We ensure that our staff have regular training to support the above.
A cookie is a small file of letters and numbers which we store on your browser or the hard drive of your computer if you agree and use the services of our Site. Cookies contain information that is transferred to your computer’s hard drive.
The type of cookies we use are analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. You can find more information at www.allaboutcookies.org and www.youronlinechoices.eu .
THIRD PARTY SITES
We use analytics service providers who assist us in understanding the usage of our website, to enable us to improve our services. The analytics provider we currently use is Google Analytics.
Our site may, from time to time, contain links to and from other websites that are not operated by us. These linked sites are not under our control and as such, we are not responsible for the privacy practices or the content of any linked websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and any Personal Data collected by the Third Party’s website will be controlled by the privacy notice of that third party and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.
ACCESSING YOUR PERSONAL DATA AND OTHER RIGHTS YOU HAVE
Under Data Protection Legislation, you have certain rights which include the right to correct, restrict/block, rectify, object, access and revoke your consent to any applicable aspect of this Policy or ask us to delete any of your Personal Data that we hold. You also have the right to data portability (i.e. to move, copy or transfer your personal data from one organisation to another). If you wish to enforce any of your rights, then please contact us by email at firstname.lastname@example.org. For further concerns in relation to you rights you may contact the Information Commissioner’s Office.
We will collect, store and process your Candidate Personal Data in accordance with your rights under any applicable data protection laws. For further information about your rights, see below:
- Subject Access Request
- You have the right to request details of the Personal Data which we hold about you and copies of such Personal Data.
- Right to Withdraw Consent
- Where you have consented to our processing of your Personal Data, you have the right to withdraw such consent at any time. In the event you wish to withdraw your consent to processing, please contact us using the details provided in the ‘Contact’ section below.
- Data Portability
- You may, in certain circumstances, request us to port (i.e. transmit) your Personal Data directly to another organisation.
- We want to ensure that Personal Data that we hold about you is accurate and up-to-date. If you think that any information we have about you is incorrect or incomplete, please let us know. We will use our best endeavours and have policies and procedures in place to try to ensure that we can rectify or update any incorrect or inaccurate Personal Data about you.
- Erasure (“right to be forgotten”)
- You have the right to have your Personal Data ‘erased’ in certain specified situations.
Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Policy. The “last updated” legend at the top of this page states when the policy was last updated and any changes will become effective upon our posting of the revised Policy.
Questions, comments and requests regarding this Policy are welcomed and should be addressed to email@example.com.