In brief

• We will respect your personal data and store it securely.
• We will never sell your personal data.
• We will remove your data if you ask us to.
• We may send you content we think is relevant or interesting to you but you can request us not to contact you at any time.
• We may use your data to contact you about information you request or to allow you to access our services.

What is the purpose of this document?

Bartholomew Advisors Ltd. collects and processes personal information about you during and after your relationship with us in order to manage that relationship. We are committed to being transparent about how we collect and use your data to meet our obligations under the General Data Protection Regulation (UK GDPR and EU GDPR if processing EU citizen’s data).

What personal information do we collect and how is it used?

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).

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

We will only use your personal information 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 we need to use your 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law

In some circumstances, you may provide us with Personal Data about others. For example, you might act as a Source and provide comments on a Candidate. Whenever you provide any such Personal Data, we rely on you to ensure that you have a lawful basis for providing such Personal Data to us, and that you have complied with applicable law and with the terms of this Policy. If you are unable to do so, please refrain from providing the Personal Data of third parties to us.

How and why do we use your Personal Data?

The purposes for which we may Process Personal Data, subject to applicable law, include:

• Recruitment activities on behalf of Clients: recruitment operations; advertising Client opportunities; providing services to our Clients; enabling Clients to understand which
• Candidates are interested in their opportunities; record-keeping; and performing background checks.
• Provision of services to you: attending meetings with you; attending telephone calls with you; and otherwise communicating with you in relation to those services.
• Training: providing you with training and preparation for interviews.
• Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) about possible opportunities in which you may be interested.
• Communications and IT operations: management of our communications systems; operation of IT security; and IT security audits.
• Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations.
• Financial management: sales; finance; corporate audit; and vendor management.
• Improving our services: identifying issues with existing services; planning improvements to existing services; creating new services.

How is your personal information collected?

We collect information through our search processes, either directly from you or from third party researchers, or through advertising media, or through recommendations from people known to us, or through references you will have been asked to provide. We may sometimes collect additional information from third parties including business and social media searches such as LinkedIn.

How we use particularly sensitive personal information

• We do not need your consent if we use special categories of your personal information to carry out our legal obligations. In limited circumstances we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

Automated Decision Making

• We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Who has access to your data?

• Your information may be shared internally, including with Partners responsible for managing and administering projects
• We may have to share your data with third parties, including our clients and third-party service providers, for example our researchers and professional advisers (eg: assessment professionals) where necessary, who may be party to confidential discussions related to an individual or a client assignment.
• We require third parties to respect the security of your data and treat it in accordance with the law. We will share your information with third parties where required by law, where it is necessary to administer our relationship with you or where we have another legitimate interest. All our third party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data Security

• Bartholomew Advisors Ltd. takes the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, or subject to unauthorised access. Where necessary, we implement appropriate network access controls, user permissions and encryption to protect data.
• Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
• We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

• We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting or reporting requirements. Details of retention periods, archiving and destruction policies for different aspects of your personal information are available in our retention policy which is available from the person responsible for data protection.

Your legal rights

• As a data subject, you have a number of rights, details of which can be found at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
• If you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent at any time. Once confirmed, we will no longer process your information for the purpose you originally agreed to, unless we have another legitimate basis for doing so in law.
• If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner (ICO) by calling their helpline on 0303 123 1113.

Accessing your data

• You will not have to pay a fee to access your personal information. However, if we think that your request is unfounded or excessive, we may charge a reasonable fee or refuse to comply with the request.
• We may need to confirm your identity or ensure your right to exercise your legal rights. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Changes to this privacy notice

• We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Queries and Further Information

• Bartholomew Advisors Ltd. is based at 23 Berkeley Square, London W1J 6HE and is the Data Processor. For any queries, please contact Simon Bartholomew at sajb@bartholomewadvisors.com