Privacy Policy

For the purpose of applicable data protection legislation, including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"), the company responsible for your personal data is Bowden Penrose Ltd, 20-22 Wenlock Road, London, England, N1 7GU (hereinafter referred to as "Bowden Penrose", "we", "our" or "us").

This privacy policy explains what Bowden Penrose do with your personal data, whether we are: assisting you to find a suitable candidate to fill a role, 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, using your data to ask for your assistance in relation to one of our candidates, or you are visiting our website.

This privacy policy describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you.

This privacy policy applies to the personal data of our website users, candidates, clients, suppliers, and other people whom we may contact in order to find out more about our candidates.

What kind of personal data do we collect?

Candidates:

In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you.

Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to match you to employment opportunities which are relevant to you. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions:

Name; age/date of birth; sex/gender; photograph; contact details; education details; employment history; details about your current remuneration, pensions and benefits arrangements; information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website; referee details; immigration status (whether you need a work permit); nationality/citizenship/place of birth; a copy of your driving licence and/or passport/identity card; diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information (provision of any such information will be strictly optional; however information you do provide will help us and our clients maintain equal opportunities best practice and identify barriers to workforce equality and diversity); extra information that you choose to tell us; extra information that your referees chooses to tell us about you; extra information that our clients may tell us about you, or that we find from other third party sources such as job sites; IP address; and the dates, times and frequency with which you access our services.

Clients:

We collect your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to ensure that our relationship runs smoothly. To ensure that we provide you with the best service possible we may also keep records of our correspondence, meetings, registered jobs and placements.

We use information about you, or individuals at your organisation, in the course of finding candidates who are most suitable in terms of complementary experience, skillset, approach and future potential for your organisation.

Suppliers:

We require contact details of relevant individuals at your organisation so that we can communicate with you; such as names, telephone numbers and email addresses. We may keep correspondence with you to assist our working relationship and also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).

Other contacts, such as referees:

In order to provide candidates with suitable employment opportunities, we require some basic background information (such as name, email address and telephone number). We only ask for very basic contact details, e.g. so that we can get in touch with you for a reference.

Website users:

We collect a limited amount of data from our website users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This may include information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular.

Please note that the above lists of categories of personal data we may collect are not exhaustive.

How do we collect your personal data?

There are two main ways in which we collect your personal data; directly from you and from third parties, as described below. We may also collect some personal data automatically; to the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements.

Candidates:

Personal data you give to us: We need to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities and should therefore save you time hearing about roles that are not relevant to you. There are numerous ways you can share your information with us; these may include: Entering your details on the Bowden Penrose website; emailing your CV to a Bowden Penrose consultant or being interviewed by them; applying for jobs through job boards which Bowden Penrose use to advertise roles; correspondence with us over LinkedIn Messenger, Skype etc.

Personal data we receive from other sources: We also receive personal data about candidates from other sources. Depending on the relevant circumstances, these may include personal data received in the following situations: Your former or current colleagues, or referees may disclose personal information about you; our clients may share personal information about you with us; we may obtain information about you from searching for potential candidate from third party sources, such as LinkedIn and other job sites; if you ‘like' our page on Facebook, ‘follow' us on Twitter or ‘connect with us' on LinkedIn, we will receive your personal information from those sites.

Clients:

Personal data that we receive directly from you: we will receive data directly from you in two ways: Where you contact us proactively, usually by phone or email; and/or where we contact you, for instance by phone, email or LinkedIn Messenger, or through our consultants' business development activities more generally.

Personal data we receive from other sources: where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including: from third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us); and from other limited sources and third parties (for example from our candidates to the extent that they provide us with your details to act as a referee for them).

Other users, such as referees:

We collect your contact details only where a candidate puts you down as a referee.

Website Users:

We may collect your data automatically via cookies when you visit our website, in line with cookie settings in your browser. When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via the website.

How do we use your personal data?

We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we'll ask for this via an opt-in or soft-opt-in. Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services. Under ‘soft opt-in' consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent.

Candidates:

The main reason for using your personal details is to match you to employment that may be suitable for you. The more information we have about you, your skillset and your ambitions, the more we can tailor our services to your requirements. We may also use your personal data for things like marketing, profiling and diversity monitoring. Where appropriate, we will seek your consent to undertake some of these activities.

We generally use candidate data in four ways: Recruitment activities; marketing & business development activities; equal opportunities monitoring; and to help us to establish, exercise or defend legal claims.

Recruitment activities: Our main area of work is executive recruitment - connecting the right candidates with the right jobs. The following list describes various ways in which we may use and process your personal data for this purpose: Collecting your data from you and other sources, such as LinkedIn; storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment; providing you with our recruitment services and to facilitate the recruitment process; assessing data about you for opportunities which we think may be suitable for you; sending your information to clients, in order to apply for jobs or to assess your eligibility for jobs; carrying out our obligations arising from any contracts entered into between us; carrying out our obligations arising from any contracts entered into between Bowden Penrose and third parties in relation to your recruitment; facilitating our invoicing processes; complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; and processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you. Please note that this list is not exhaustive.

Marketing activities: We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other candidates with jobs. In particular, we may wish to use your data for the following purposes; to: enable us to develop and market other products and services; and market our full range of recruitment services to you - potentially also as our future client or supplier. Please note that this list is not exhaustive.

Equal opportunities monitoring and other sensitive personal data: We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we may (in appropriate circumstances and in accordance with local law and requirements) collect about you comes under the umbrella of "diversity information". This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. Where appropriate and in accordance with local laws and requirements, we'll use this information on an anonymised basis to monitor our compliance with equal opportunities best practice. We may also disclose this (suitably anonymised where relevant) data to clients where this is contractually required or the client specifically requests such information to enable them to comply with their own employment processes. This information is what is called ‘sensitive' personal information and stricter data protection rules apply to it. We therefore need to obtain your explicit consent before we can use it. We'll ask for your consent by offering you an opt-in. This means that you have to explicitly and clearly tell us that you agree to us collecting and using this information.

Clients:

We use your personal data to help us to provide you with our services or for us to approach you about engaging our services. We will collect information on you such as contact details and job role and other publicly available information and then use this to help us maintain our relationship, help us to fulfil a contract or for business development.

Suppliers:

We use the personal data of suppliers to ensure that the arrangement between us can be properly maintained and implemented.

Other Users, such as Referees:

We use referees' personal data to help verify our candidates' details and qualifications. We may also use referees' personal data to contact them in relation to recruitment activities that may be of interest to them.

Who do we share your personal data with?

Where appropriate we may share your personal data, in various ways and for various reasons, with the following categories of people: Individuals and organisations who hold information related to your reference, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies; Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation); Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems); Third party outsourced IT and document storage providers where we have appropriate protections in place; Marketing technology platforms and suppliers.

Candidates:

We may share your personal data with various parties, in various ways and for various reasons. We share your personal data with the client who has a position to fill, in order to determine with the client whether you are a good fit for the available position. We may also conduct reference checks on you to verify the information you have provided; where we do this your details are shared with the referee you have specified for confirmation. Unless you specify otherwise, we may also share your information with associated third parties such as our service providers where we feel this will help us to provide you with the best possible service.

Clients:

We will share your data, subject to any pre-agreed restrictions, with prospective candidates and third party contacts who may assist with identifying such candidates.

Suppliers:

Unless you specify otherwise, we may share your information with associated third parties such as our service providers and organisations to whom we provide services.

How do we safeguard your personal data?

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with and appropriately report any suspected data breach.

If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately.

For how long do we keep your personal data?

We will securely delete your personal data from our systems if we have not had substantial contact with you (or, where appropriate, the company you are working for or with) for a period of five years.

We will securely delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.

When we refer to "substantial contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a candidate, we will consider there to be substantial contact with you if you submit your updated CV onto our website or via e-mail to us. We will also consider it substantial contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as substantial contact - this will only occur in cases where you click-through or reply directly.

What are our legal bases for processing your data?

Legitimate Interests - Article 6(1)(f) of the GDPR applies here, stating that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data." We don't think that any of our described activities prejudice individuals in any way - instead helping us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis.

Candidates:

We think it's reasonable to expect that if you are looking for employment, have posted your professional CV information on a job board or professional networking site, or sent us your details by e-mail, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our clients' vacancies.

Once you reach the final stages and you may get the job, your prospective employer may also want to check any information you've given us (such as the results from psychometric evaluations or skills tests) or to confirm your references, qualifications and criminal record, to the extent that this is appropriate. We need to do these things so that we can function as a profit-making business, and to help you and other candidates in your appointment to suitable positions.

We have to make sure our business runs smoothly, so that we can carry on providing services to candidates like you. We therefore also need to use your data for our internal administrative activities, like invoicing.

We have our own obligations under the law, which it is a legitimate interest of ours to insist in meeting. If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.

Clients:

To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements.

Suppliers:

We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.

Other users, such as referees:

If you have been put down by a candidate as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary as an organisation offering recruitment services.

What rights do you have in relation to the data which we hold on you?

By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country. Within the UK and the EU you have the right: to be informed; of access; to rectification; to erasure; to restrict processing; to data portability; to object to processing; to lodge a complaint; and to withdraw consent. Your right to be informed, describes your right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we're providing you with the information in this Policy. To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled).

Please note that we may keep a record of your communications to help us resolve any issues which you raise.

Data Access Requests: You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for so doing.

Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to securely remove your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data securely but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so. Normally, the information must meet one of the following criteria: the data is no longer necessary for the purpose for which we originally collected and/or processed them; where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing; the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR); it is necessary for the data to be deleted securely in order for us to comply with our legal obligations as a data controller; or if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing. We would only be entitled to refuse to comply with your request for one of the following reasons: to exercise the right of freedom of expression and information; to comply with legal obligations or for the performance of a public interest task or exercise of official authority; for public health reasons in the public interest; for archival, research or statistical purposes; or to exercise or defend a legal claim. When complying with a valid request for the removal of data we will take all reasonably practicable steps to securely delete the relevant data.

Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or State public interest. You are entitled to request that we restrict the processing of your personal data where you dispute the accuracy of the personal data that we are processing about you; here our processing of your personal data will be restricted for the period during which the accuracy of the data is verified. You are entitled to request that we restrict the processing of your personal data where you object to our processing of your personal data for our legitimate interests; here you can request that the data be restricted while we verify our grounds for processing your personal data. You are also entitled to request that we restrict the processing of your personal data where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and, where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims. If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will notify you before lifting any restriction on processing your personal data.

Right to data portability: you have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new service provider, we will act reasonably in enabling you to move, copy or transfer your information easily between our systems and yours.

Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply. This right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes. The "legitimate interests" and "direct marketing" categories above are the ones most likely to apply to our website users, candidates, clients and suppliers. If your objection relates to us processing your personal data because we deem it necessary for our legitimate interests, we must act on your objection by ceasing the activity in question unless: We can show that we have compelling legitimate grounds for processing which overrides your interests; or we are processing your data for the establishment, exercise or defence of a legal claim. If your objection relates to direct marketing, we must act on your objection by ceasing this activity.

The right to lodge a complaint: You should in the first instance contact us to resolve matters related to your privacy and data use and protection. If you believe our handling of the matter is unsatisfactory, you have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for profiling your suitability for certain roles), or consent to market to you, you may withdraw your consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.