Ascent Professional Services provides worldwide recruitment services, primarily in the management consulting industry.
APS (‘we’; ‘us’; ‘our’) take your privacy very seriously and are committed to protecting the personal information that we collect. We will take appropriate care to keep your information secure and to prevent any unauthorised access or use of it. We implement various security measures to maintain appropriate controls over the processing and transfer of personal data.
This Policy was last revised on: 1st May 2018.
How is personal data collected?
APS collect personal data in a number of ways. Most commonly these include:
§ Registration with APS as a candidate for employment through our website.
§ Directly from candidates via email, phone call or face to face
§ Prospective future candidates for employment or employers whose data is gleaned from publicly available sources (e.g. LinkedIn or job boards).
What personal data is collected?
The type of personal data APS collect will depend on the circumstances in which that data is collected.
The standard personal data APS collect and store is: your name, your employer, your job title, and your contact details (e.g. email address, telephone number).
Additional data is collected if you have registered with APS as a candidate for employment. Such data is likely to include a copy of your CV, salary details and expectations, motivations for moving, right to work documents, details of applications etc.
Legal basis for processing data and the purpose of processing data
APS have a legitimate interest for processing personal data, given that it is necessary to process personal data in order to provide our services to you. As long as your data protection rights are not infringed, APS are allowed to process your data when it is in the interests of the business to do so.
The precise purpose of processing personal data will depend on the circumstances in which that personal data is collected.
APS will only process your personal data for the reason for which you provided it or for reasons that are directly related to this reason. For example, when you register as job seeker with us, we will use your personal data to assess your skills and experience for employment opportunities, to contact you about suitable roles, to provide you with career guidance, and to put you forward for positions when you give us your consent to do so.
Similarly, when we collect personal data from an employer, we will collect and process the personal data necessary to provide recruitment services to you; to discuss roles with potential candidates and to submit applicants to the prospective employer.
Use of personal data for direct marketing
When we collect personal data from you, we welcome the opportunity to share with you market intelligence in the form of Newsletters, Market Reports, Salary Surveys etc. You may withdraw your consent from receiving such communications at any time by using the facility to ‘unsubscribe’ included in the email or communication concerned.
Who can access the personal data we collect?
In order to provide our services to you, your personal data will typically be accessible by other employees of APS as well as the contact by whom the data was originally collected.
Disclosure of personal data to third parties
Personal data is disclosed to other companies (‘third parties’) depending on the reason for which that personal data is primarily held, or for a related reason. This will be for the reason for which you provided it to us; for example when registered as a candidate with us, in order to provide your data to a prospective employer once you have confirmed that you would like to apply to an available position or where you have otherwise agreed we may disclose it.
In the event of you being registered as a candidate with APS, and asking us to make an application outside of the country from which you are applying, your personal data will be sent to employers in that country. Please be aware that the degree of protection of your personal data in a different country may not be the same as in your country of residence. APS will only transfer personal data to countries outside the European Economic Area (‘EEA’) for the purposes of providing work-finding or recruitment services. This will be with the permission of the relevant data subject and where the risk to the rights of the data subject is low. The EEA comprises the EU member states, plus Norway, Iceland and Liechtenstein.
Personal data is also processed to Invenias, a cloud-based customer relationship management (CRM) and operations software company, who manage our computerized database and perform functions on our behalf as data processors. Invenias have demonstrated to us that they have appropriate safeguards and security measures in place to ensure their compliance with GDPR.
APS will retain your personal data only for as long as is necessary to comply with our statutory and contractual obligations and in accordance with our legitimate interests as a data controller. Different laws require us to keep different data for different periods of time.
APS will typically retain personal data for up to ten years from the date of last contact, unless it is deemed necessary to retain such personal data for longer. We have chosen ten years as the specialist employment markets for which we provide ongoing advice and recruitment services do not typically feature a high turnover of staff. Therefore it is in our legitimate interests to retain the data so that we can provide a long term continuous offering for those who may wish to engage APS’s services just once or twice during the course of their careers.
Where we have sought explicit consent for the collection and processing of sensitive personal data, this will only be stored and processed for the defined period of time that you have given your explicit consent for such to be stored and processed.
Please be aware that you have the following data protection rights: the right to be informed about the personal data APS processes on you; the right of access to the personal data APS processes on you; the right to rectification of your personal data; the right to erasure of your personal data in certain circumstances; the right to restrict processing of your personal data; the right to data portability in certain circumstances; the right to object to the processing of your personal data that was based on a public or legitimate interest; the right not to be subjected to automated decision making and profiling; and the right to withdraw any given consent at any time.
You may contact APS to seek access to, rectify, and/or request deletion of the personal data we hold on you. We will require that you provide suitable identification.
To make a request to access your personal information, please email us with your request and provide verification of your identity. We will provide this information within 30 days, excepting any information that would interfere with the privacy rights and confidentiality of other individuals or companies.
Your co-operation in helping us store accurate personal data for you is very valuable to us. Please email us to rectify any personal data we hold on file you, for example change of name, address details, or to provide us with an up-to-date CV.
Should you wish for your file to be deleted, we will process this where possible, but please be aware that there may be occasions where we may not be required to do so, particularly where your file also includes financial/employment records that we need to keep for periods up to six years.
Should you wish to access, rectify or delete the personal data we hold, please email APS’s Data Protection Officer.
How to make a complaint
If you believe that this policy has been breached in any way, please write to or email APS’s Data Protection Officer, verifying your identity, and setting out in as much as detail as possible the detail of the personal data affected, and the reason for and circumstances of your complaint. We will provide a written response within 30 days after concluding an internal investigation. We may contact you should we need any additional information.
You also have the right to raise any concerns with the Information Commissioner’s Office in the UK on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.
Contact APS’s Data Protection Officer
Contact: James Liddiatt
Address: Chester House, Fulham Green, 81-83 Fulham High Street, Fulham, London. SW6 3JA
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