ADWAY ASSOCIATES – EXECUTIVE SEARCH LTD (‘the Company’) PRIVACY POLICY STATEMENT 

At Adway Associates – Executive Search Ltd we are committed to protecting your privacy. 

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The GDPR aims to harmonise data protection legislation across the European Union, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate. 

The Company’s Privacy Policy describes how we collect, use and process your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a service from you or if you are visiting our website. 

You are not required to provide any personal information to use or view the public pages of our website. However, where you provide your personal information, such as to contact us generally, this Privacy Statement will govern how we collect, use and process your provided information. 

Each time you provide personal information through our website or your details are captured via one of our staff, you will be asked to confirm that you have read and understood this Privacy Statement. Since it is not our intention to collect personal information from children, no child specific policy is described. 

Please read our Privacy Statement below.

Collection, use and processing of your personal information

On some pages and sites, we collect personal information, such as your e-mail address, name, home or work address or telephone number. For registration for submission to one of our clients, we may also collect information from your uploaded CV or online work history profile. Information collected by The Company may be combined with information obtained from other sources. 

We collect, use and process your personal information to provide certain services for you, such as responding to your questions, providing information for you electronically in response to your requests and assessing your suitability for current or future roles. In addition to sending information you request, we may also use your personal information to communicate with you about other roles we believe may be of interest. 

We do not use, collect, determine or disclose sensitive personal information, such as race, religion, or political affiliations, other than as required by law.

Use of your personal information

The Company and our clients collect and use your provided personal information to deliver the services you have requested. 

The sharing, storage and processing of your personal information may take place in the United Kingdom or any other country in which the Recipients are located or maintain facilities. Some overseas countries do not have data protection legislation equivalent to that in force in the European Union. 

By using this site and submitting your personal information, you consent to any such sharing and transfer of your personal information. 

The Company may access and/or disclose your personal information if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on the Company or the site; (b) protect and defend the rights or property of the Company; or (c) act under exigent circumstances to protect the personal safety of users of The Company services or members of the public.

Automated Decision Making or Profiling

We do not undertake automated decision making or profiling. We do use our computer systems to identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process.

Additional services

We also use your personal information to inform you of other roles/Candidates available from the Company. 

The Company does not sell, rent or lease its customer lists to third parties or marketing organisations. The Company may, from time to time, contact you on behalf of external clients about a particular offering that may be of interest to you. In those cases, your personal information (e-mail, name, address, telephone number) is not transferred to the third party. The Company shares such data to ensure that the services you and our clients engage us to perform are carried out as expected. 

The Company is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Opt-in/Opt-out electronic mail

Our electronic mail programme operates on an opt-in basis. You will receive regular electronic mail from The Company when you opt-in by providing your details via one of the registration forms on our website. Upon registration, the information you have requested will be sent by electronic mail and as frequently as it is produced or available. You will be able to opt-out of receiving further electronic mail by using the unsubscribe feature. We will provide you with a link to the unsubscribe feature in all our electronic mail.

Security of your personal information

The Company is committed to protecting the security of your personal information. We use a variety of security technologies, contractual controls, industry leading standards, including HMG’s Cyber Essentials Certificate and ISO27001, amongst others. Our procedures are verified to help protect your personal information from unauthorised access, use, or disclosure. 

Your rights

Under the GDPR, you have the right to: 

• Request access to your personal information which involves confirming with us whether we are processing your personal data and if we are, to request access to that personal data including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. We do have to take into account the interests of others though, so this is not an absolute right. 
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. 
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). 
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. To stop receiving marketing communications from us or change your preferences please contact us at info@adwayassociates.co.uk 
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. 
• Request the transfer of your personal information to another party in certain formats, if practicable. 
• Withdraw consent to processing at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 
• Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. If you think we are mishandling your personal data. The ICO can be contacted through this link: https://ico.org.uk/concerns/ 
• You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 
• We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 
• We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

How long we keep your data

The Company will retain your personal data only for as long as is necessary. We maintain specific data management, retention policies and procedures, so that personal data is deleted after a reasonable time according to the following retention principles: 

• The Company will retain your data as long as we have an ongoing relationship with you (in particular, if you are a current client or contractor). 
• The Company will keep the data while your account is active or for as long as needed to provide services or information to you. 

Changes to this statement

We will occasionally update this Privacy Statement to reflect company and customer feedback. If there are material changes to this Statement or in how the Company will use your personal information, we will prominently post such changes prior to implementing the change. We encourage you to periodically review this Statement to be informed of how we are protecting your information. 

Contact information

If you have any questions in relation to this statement, or wish to exercise your rights relating to it, please contact us.