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Privacy Policy

Privacy Policy & Cookie Policy

Overview

This Privacy Policy describes how we collect, use and process your personal data and how we comply with our legal obligations to you in compliance with applicable data protection law, in particular the General Data Protection Regulation (EU) (GDPR). Your privacy is important to us and we are committed to protecting and safeguarding the data privacy rights of our clients, candidates, suppliers, third parties, employees and users of our website. We will ensure that your information is only used for the purposes set out in this policy.

About Us

Wheale Thomas Hodgins Plc is a boutique generalist executive search and selection firm (registration number 02470369). The registered office is based in Bristol (full contact details are outlined at the end of this document). In this policy document any reference to ‘WTH’, ‘we’ or ‘us’ refers to Wheale Thomas Hodgins Plc.

Personal Data We Collect 

Clients
Name
Telephone/mobile
Email

Candidates
Name
Telephone/mobile
Email
Address
Education
Qualifications
Salary and Benefits Package
Family Circumstances
Reasons for leaving/previous roles
References/Referees
Opinions/interview notes

Suppliers
Name
Telephone/mobile
Email
Address
Bank details

Third Parties
Name
Telephone/mobile
Email
Bank Details

Employees
Name
Telephone/mobile
Email
Address
Date of Birth
Education
Qualifications
Salary and Benefits Package
Family Circumstances
Reasons for leaving/previous roles
References/Referees
Opinions/interview notes
Bank details
Next of Kin

How We Use Your Personal Data

Clients
Basic information about you or individuals within your organisation is collected for business development purposes, in order to provide services to you such as sourcing candidates for positions within your organisation and to ensure contracts are implemented correctly. We may also send you marketing/event emails of which you have the right to opt out of.

Candidates
In order to make you aware of and match you with employment opportunities relevant to you, we need to process certain information about you. We may store your details on our database for future contact, to assess eligibility for a position, to carry out contractual obligations, verifying details using third parties e.g. psychometrics or reference requests and to send relevant marketing emails unless you opt out.

Suppliers
In order to conduct business with our suppliers we need to retain the contact details of relevant individuals at the organisation to communicate with you. We also use your information to ensure the contracts are implemented correctly and to comply with legal obligations. In some cases we also need additional information such as bank details so that we can pay for services and products provided to us.

Third Parties
We generally ask for basic contact details so that we can get in touch with third party organisations/ individuals e.g. contacting referees and verifying details such as qualifications.

Employees
We retain the details of past and present employees for purposes such as payment, training, referencing, health and safety and to process contracts.


How We Collect Your Personal Data

We collect the information directly from you via email, phone, face-to-face (e.g. event, interview, meeting), our website and applications to adverts on LinkedIn and other job boards. We also gather information from third parties (which includes referees), from publicly available resources and job boards/LinkedIn.

Who We Share Your Personal Data With

Clients
Client details will be shared with candidates (unless confidential, requiring a non-disclosure agreement) at initial contact or named within the advert. Further contact details may be shared at client interview stage.

Candidates
Details will be shared with employees of Wheale Thomas Hodgins. Should candidates successfully progress through the recruitment process and upon receiving prior consent, details will be shared with the client. 

Suppliers
Limited data will be shared with employees.


Third Parties
Limited data will be shared with employees and clients for referencing purposes. 

Employees
Some details may be shared with other employees and clients. There may also be times when details are shared with suppliers and third parties mainly in relation to internal processing activities such as payroll and IT maintenance.

How We Safeguard Personal Data

We have in place appropriate technical and organisational measures designed to prevent unauthorised access to and misuse of your personal data. If you believe there is any misuse, loss or unauthorised access, please inform us immediately.

How Long We Keep Personal Data For

The period depends on the purpose it was collected and the legal basis we are processing the data. We will not keep your personal information longer than necessary for our business purposes or for legal requirements. 


Where we have obtained your consent to keep your details on our database for future recruitment, business development or marketing purposes, we will keep your details on file for 3 years. We will contact you towards the end of this period to review consent.

Individual Rights

Please see below an overview of your individual rights. For further information please refer to the ICO’s website www.ico.org.uk Please keep us informed on any changes to your personal information during the time we hold your data for, so that we may keep it accurate and up to date. Contact details can be found at the end of this document.

Right to Object
Should we be using your data as we see it necessary for our legitimate interests, but you do not agree, you can object. We will respond to this request within 30 days (unless there are extenuating circumstances). If you object to processing your data for your legitimate interests, we must stop unless our grounds for processing override your interests or where there is a legal reason for doing so. We must stop if you object to marketing correspondence.

Right to Withdraw Consent
You have this right if we obtained your explicit consent to process your personal data and you may withdraw consent at any time.

Data Subject Access Requests
You are able to ask us what information we hold about you at any time and there is no charge for doing so unless there are extenuating circumstances. Requests will be actioned within 30 days (unless excessive or unfounded). We have the right to decline your request and will explain why, should this situation arise. We may ask you to verify your identity before doing so.

Right to Erasure
The data may no longer be necessary for the original purpose of collecting it. You may have withdrawn your consent to us holding/ processing your data, the data has been unlawfully processed or is necessary due to our legal obligations or we may have no overriding legitimate reasons for processing. Response to such a request will be within 30 days although this time frame may be extended depending on circumstance. Of course if we agree with the request your data will be deleted.

Right to Restrict Processing
Should you dispute the accuracy of the data we hold on you, processing will be restricted until this can be rectified. Should you object to the processing of your data under legitimate interests, processing would be restricted until we can confirm these grounds. If our processing is unlawful we would need to restrict processing your data rather than erasing it. Your data will be held until you consent or processing is legally necessary. We will notify clients, employees and third parties where appropriate of this restriction unless the effort in doing so is disproportionate.

Right to Rectification
You can ask us to rectify inaccurate or incomplete data and update clients, employees or third parties as appropriate unless this would be a disproportionate effort.
 
Right of Data Portability
You can transfer your data from us to another data controller. This can either be sent, password protected, directly to the other controller or to you in a commonly used format. This is applicable to data that you have provided to us and personal data we process based on your consent.

Legal Basis for Processing Your Data

Legitimate Interests

We can process your data where it is necessary for the purposes of legitimate interests pursued by us, unless these interests are overridden by the interests or fundamental rights or freedoms of which require protection of personal data. This legal basis shall apply to the processing activities (with the exception being consent as shown below) concerning clients, candidates, suppliers, third parties and employees.

Consent
Where candidates have been through the search or selection process for a particular role, we may ask you for explicit consent for your data to be retained so that it may be assessed for future opportunities.

Cookie Policy

Website
This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies with all UK national laws and requirements for user privacy and GDPR.

Cookie Policy
This website uses cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.

The cookies in use to deliver Google Analytics service are described below.

Cookie Title Description
__utma
__utmb
__utmc
__utmv
__utmz

Google Analytics
These cookies are used to store information, such as what time your current visit occurred, whether you have been to the site before, and what site referred you to the web page.
These cookies contain no personally identifiable information but they will use your computer’s IP address to know from where in the world you are accessing the Internet.
Google stores the information collected by these cookies on servers in the United States. Google may transfer this information to third-parties where required to do so by law, or where such third-parties process the information on Google’s behalf.

Opt-out
In order to provide website visitors with more choice on how data is collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to stop data being sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not affect usage of the website in any other way. A link to further information on the Google Analytics Opt-out Browser Add-on is provided below for your convenience.

http://tools.google.com/dlpage/gaoptout?hl=None

For more information on the usage of cookies by Google Analytics please see the Google website. A link to the privacy advice for this product is provided below for your convenience.

http://www.google.com/analytics/learn/privacy.html

Disabling Cookies
If you would like to restrict the use of cookies you can control this in your Internet browser. Links to advice on how to do this for the most popular Internet browsers are provided below for convenience and will be available for the Internet browser of your choice either online or via the software help (normally available via key F1).

Internet Explorer
http://windows.microsoft.com/en-GB/windows7/Block-enable-or-allow-cookies
Google Chrome
https://support.google.com/chrome/bin/answer.py?hl=en-GB&answer=95647&p=cpn_cookies
Mozilla Firefox
http://support.mozilla.org/en-US/kb/Blocking%20cookies
Apple Safari
http://docs.info.apple.com/article.html?artnum=32467

Contact & Communication
Users contacting this website and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed in GDPR requirements as of 2018, 3 years with consent. Every effort has been made to ensure a safe and secure form to email submission process but advise users using such form to email processes that they do so at their own risk.

Email marketing campaigns published by this website or its owners may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity [this is not a comprehensive list].

This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.

In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003 subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will by detailed instead.

External Links
Although this website only looks to include quality, safe and relevant external links, users are advised adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text / banner / image links to other websites, similar to; www.kingstrains.co.uk or Kings Trains Models.)
The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

Shortened Links in Social Media:
This website and its owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy urls [web addresses] (this is an example: http://bit.ly/zyVUBo).

Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.

Contact Information

Contact Wheale Thomas Hodgins:

Data Protection Officer
Wheale Thomas Hodgins Plc
13 Berkeley Square
Clifton
Bristol
BS8 1HB

Telephone: 0117 927 2311
Email: admin@wth.co.uk

Lodge a complaint with the ICO:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Email: casework@ico.org.uk


This documented will be constantly reviewed. Please refer to the Privacy Policy on our website (www.wth.co.uk) for the latest version.


This policy has been approved & authorised by:


Tony Hodgins

Finance Director

May 2018

© Copyright 2018 Wheale Thomas Hodgins PLC- All Rights Reserved