Introduction
Welcome to Carlyle Associates’ (T/A Native Talent) privacy notice.
Carlyle respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, tell you about your privacy rights and how the law protects you when:
we provide to you our executive search and interim recruitment services (“Services”); and
you visit our website at http://www.carlyleassociates.co.uk/ (regardless of where you visit it from) (“Site”).
To help makes things clearer we use the following terms to describe the different categories of individuals whose personal data we may collect:
Browser: means any person accessing our Site.
Client: means a business or organisation who uses the Services for hiring Candidates.
Candidate: means an individual who is using the Services to be hired by our Clients.
Contacts: means an individual who has previously engaged us for our Services, or has been engaged as part of our Services offerings.
Employee: means an employee, agent or independent contacts of the Client who is authorised by the Client to use the Services in hiring Candidates.
We reserve the right to change this privacy policy from time to time by changing it on the Site.
Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data through your use of the Site and Services, including any data you may provide through the Site when you are using our Services.
The Site is not intended for children and we do not knowingly collect data relating to children.
Controller
Carlyle Associates Limited is the controller and responsible for your personal data (collectively referred to as “Carlyle”, “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights set out below. You can contact the data privacy manager by using the contact details set out below.
Contact details
Our full details are:
Carlyle Associates Limited, trading as Native Talent
Name or title of data privacy manager: Carol-Ann Searles
Email address: info@carlyleassociates.co.uk
Postal address: 32 Charlotte Square, Edinburgh, Scotland, EH2 4ET
Telephone number: 0131 625 5000
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 24th May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every Site you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, title and date of birth.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Employment Data: includes start date, location of employment or workplace, performance information and compensation history.
Recruitment Data: copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process, employment records (including job titles, work history, working hours, training records and professional memberships).
Financial Data includes bank account details.
Transaction Data includes details about payments to and from you and other details of Services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site.
Profile Data which may include your unique account reference number, preferences, feedback and survey responses.
Usage Data includes information about how you use our Site and Services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature or the number of products that are purchased. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
We collect information about criminal convictions and offences in order to assess your suitability as a Candidate. We only process such information as required under the relevant employment laws as part of our legitimate interest to comply with such laws.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we may have to cancel a product or Service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for our Services;
attend an event with us;
request marketing to be sent to you; or
give us some feedback.
Automated technologies or interactions. We do not use automated technologies as part of our services.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
analytics providers such as Google based outside the EU;
advertising networks; and
search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from event partners and publicly availably sources such as LinkedIn and the Electoral Register based inside the EU.
Identity and Contact Data, as well as information about criminal offences and convictions, from criminal and identity search providers such as Know Your Candidate.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Data Used | Legal Basis |
| To register you as a new Client (through your Employee) or Candidate, including prospective Candidates | (a) (a) Identity
(b) (b) Contact (c) (c) Employment (d) (d) Recruitment (e) (e) Financial |
Necessary for the performance of our contract with you |
| To process and deliver the Services:
(a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) for Candidates, to provide advice on available opportunities and details on current openings, and where appropriate sending to our Clients and relevant third parties (d) for Clients (and your Employees), to provide advice on the available Candidates |
(a) Identity
(b) Contact (c) Employment (d) Recruitment (e) Financial (f) Transaction (g) Profile |
(a) Necessary for the performance of our contract with you
(b) Necessary for our legitimate interests (to recover debts due to us) (c) Necessary for the legitimate interests of others (preventing fraud) |
| To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review (c) Provide you with information on upcoming events, potential opportunities and available Candidates, as well as organising your attendance at our events. |
(a) Identity
(b) Contact (c) Profile (d) Marketing and Communications |
(a) Necessary for the performance of our contract with you
(b) Necessary for our legitimate interests (to keep our records updated, study how Clients and Candidates use our Services and to improve our Services into the future) (c) Necessary for the legitimate interests of others (presenting the best possible Candidates) (d) Necessary to comply with a legal obligation |
| To administer and protect our business and our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact (c) Financial (d) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with our legal obligations |
| To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how Customers and Users use our Goods and Services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our Site, products/Services, marketing, customer relationships and experiences | (a) Technical
(b) Usage |
Necessary for our legitimate interests (to define types of Candidates and Clients for our Services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or Services that may be of interest to you | (a) Identity
(b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our Services, and grow our business) |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which events, content, products and services may be relevant for you and send to you through our marketing messages.
You may receive marketing messages from us if you have requested information from us, attended an event with us or purchased Services from us and you have not opted out of receiving that marketing.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at info@carlyleassociates.co.uk.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/Service purchase, warranty registration, product/Service experience or other transactions.
Cookies
When you interact with the Site, we try to make that experience simple and meaningful. When you visit our Site, our web server sends a cookie to your computer or mobile device (as the case may be). Cookies are small pieces of information which are issued to your computer or device when you visit a website or access or use a mobile application and which store and sometimes track information about your use of the Site. A number of cookies we use last only for the duration of your Site session and expire when you close your browser. Other cookies are used to remember you when you return to the Site and will last for longer.
Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. Please note, however, that by blocking or deleting cookies used on the Site, you may not be able to take full advantage of the Site.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party Service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
We do not transfer any personal data outside the European Economic Area (“EEA”).
If we may ever need to transfer your Personal Data to clients or third parties in countries outside the EEA we will inform you beforehand. If we were to transfer data to a country which may not have been deemed to provide adequate data protection standards by the European Commission, we shall ensure that we have the proper safeguards in place to protect your Personal Data. Any data transferred by us or our Client’s outside of the EEA shall be done only where necessary for the performance of the contract we have with our Clients and Candidates.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Access to information: You have the right to request a copy of the information Carlyle holds about you.
Ensuring accuracy of information: Carlyle wants to make sure that your personal information is accurate and up-to-date. You may ask Carlyle to correct or complete information that is inaccurate or incomplete.
Right to erasure: You may have a right to erasure, which is more commonly known as the ‘right to be forgotten’. This means that in certain circumstances you can require Carlyle to delete personal information held about you.
Ability to restrict processing: You may also have the right to require Carlyle to restrict Carlyle’s use of your personal information in certain circumstances. This may apply, for example, where you have notified Carlyle that the information Carlyle holds about you is incorrect and you would like Carlyle to stop using such information until Carlyle has verified that it is accurate.
Right to data portability: You may have the right to receive personal data Carlyle holds about you in a format that enables you to transfer such information to another data controller (e.g. such as another service provider).
Review by an independent authority: You will always have the right to lodge a complaint with a supervisory body, including ICO as listed above.
Preventing direct marketing: Carlyle does not sell your personal data. From time to time, Carlyle may send emails containing information about new features and other news about us. This is considered direct marketing. Carlyle will always inform you if Carlyle intends to use your personal data or if Carlyle intends to disclose your information to any third party for such purposes.
Objecting to other uses of your information: You may also have the right to object to Carlyle’s use of your information in other circumstances. In particular, where you have consented to Carlyle’s use of your personal data, you have the right to withdraw such consent at any time.
If you would like further information on how you can exercise these rights, please email us at info@carlyleassociates.co.uk
No fee usually required
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.
What we may need from you
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.
Time limit to respond
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.
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