KYNIGOS PARTNERS LTD
PRIVACY POLICY
Introduction
Welcome to Kynigos Partners Ltd’s privacy policy.
Kynigos Partners Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our recruitment services as a candidate or client and tells you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Kynigos Partners Ltd collects and processes your personal data when you use this website (including any data you may provide through this website when you sign up to receive our newsletter or job alerts) or our recruitment services, whether as a candidate or client.
This website and our services are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Candidates should note that potential employers with whom their data is shared are data controllers in their own right and will use candidate data in accordance with their own privacy policies. Where a potential employer has provided us with a copy of their privacy policy this will be provided to candidates at the time their data is shared.
Controller
Kynigos Partners Ltd is the controller and responsible for your personal data (referred to as "Kynigos", "we", "us" or "our" in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: Kynigos Partners Ltd
Email address: honor@kynigos.partners
Postal address: 288 Bishopsgate, London, EC2M 4QP
Telephone number: +44(0) 20 4513 4500
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 policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in June 2020.
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 website 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 website, we encourage you to read the privacy policy of every website you visit.
Purpose of this privacy policy
This privacy policy aims to give you information on how Kynigos Partners Ltd collects and processes your personal data when you use this website (including any data you may provide through this website when you sign up to receive our newsletter or job alerts) or our recruitment services, whether as a candidate or client.
This website and our services are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Candidates should note that potential employers with whom their data is shared are data controllers in their own right and will use candidate data in accordance with their own privacy policies. Where a potential employer has provided us with a copy of their privacy policy this will be provided to candidates at the time their data is shared.
Controller
Kynigos Partners Ltd is the controller and responsible for your personal data (referred to as "Kynigos", "we", "us" or "our" in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: Kynigos Partners Ltd
Email address: honor@kynigos.partners
Postal address: 288 Bishopsgate, London, EC2M 4QP
Telephone number: +44(0) 20 4513 4500
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 policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in June 2020.
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 website 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 website, we encourage you to read the privacy policy of every website you visit.
2. 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:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 policy.
We only collect Sensitive Data about candidates where this is strictly necessary in order to identify appropriate roles for a candidate or is required as part of a recruitment process.
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 goods or services). If you are a candidate we may be unable to put you forward for job roles.
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, marital status, title, date of birth and gender.
-Contact Data includes billing address, postal address, email address and telephone numbers.
-CV Data includes information contained in your CV or application form and cover letters or obtained during discussion or interviews with you.
-Financial Data includes bank account and payment card details.
-Transaction Data includes details about payments to and from you and details of services we have provided to you.
- Profile Data includes enquiries made by you and services provided to you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Sensitive Data means information about your race or ethnicity, religious beliefs, sexual orientation, trade union membership, political opinions, health and criminal convictions and offences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 policy.
We only collect Sensitive Data about candidates where this is strictly necessary in order to identify appropriate roles for a candidate or is required as part of a recruitment process.
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 goods or services). If you are a candidate we may be unable to put you forward for job roles.
3. 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, CV, Financial and Sensitive Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
If requested by a client we may on occasion undertake detailed background searches against individual candidates using third party service providers such as Kroll. Such searches are only undertaken when specifically requested by a client and not as a matter of routine. If such a search is requested, it will be discussed with the candidate and full information provided before it is undertaken. Where possible we will arrange for search results to be sent from the service provider directly to the client. Where this is not possible, we will delete the search report from our system once it has been sent on to the client.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, CV, Financial and Sensitive Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Engage with us as a candidate
- Engage with us as, or on behalf of, a client seeking candidates;
- request notifications relevant to your job/candidate search;
- request marketing to be sent to you;
- enter a survey; or
- give us feedback or contact us.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Contact, Financial and Transaction Data from providers of payment services.
- Identity and Contact Data from data brokers or aggregators such as Lushr.
- Identity and Contact Data from individuals recommending you as a potential candidate.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.
- Identity, Contact, CV and Profile Data from social media sites you use such as LinkedIn
If requested by a client we may on occasion undertake detailed background searches against individual candidates using third party service providers such as Kroll. Such searches are only undertaken when specifically requested by a client and not as a matter of routine. If such a search is requested, it will be discussed with the candidate and full information provided before it is undertaken. Where possible we will arrange for search results to be sent from the service provider directly to the client. Where this is not possible, we will delete the search report from our system once it has been sent on to the client.
4. 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:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data.
We will use your Sensitive Data where we have your explicit consent to do so. You have the right to withdraw consent 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
|
Type of data |
Lawful basis for processing
including basis of legitimate interest
To
register you as a new client seeking candidates
(a) Identity
(b) Contact
(b) Contact
Performance
of a contract with you
To deliver services to you as a client seeking candidates:
(a) collect details of potential candidates including personal recommendations and references and market intelligence regarding individuals
(b) Communicate with you regarding potential candidates
(c) Communicate with you regarding the recruitment process and negotiation of terms
(d) Manage payments, fees and charges
(e) Collect and recover money owed to us
(a) collect details of potential candidates including personal recommendations and references and market intelligence regarding individuals
(b) Communicate with you regarding potential candidates
(c) Communicate with you regarding the recruitment process and negotiation of terms
(d) Manage payments, fees and charges
(e) Collect and recover money owed to us
| (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to provide recruitment services and recover debts due to us)
(b) Necessary for our legitimate interests (to provide recruitment services and recover debts due to us)
To
register you as a new candidate seeking work opportunities
(a) Identity
(b) Contact
(b) Contact
Necessary
for our legitimate interests (to provide recruitment services)
To deliver services to you as a candidate:
(a) Identification of appropriate opportunities
(b) Assessment of your suitability for opportunities
(c) Communicate with you regarding potential opportunities
(d) Submission of applications and negotiation of terms
(a) Identification of appropriate opportunities
(b) Assessment of your suitability for opportunities
(c) Communicate with you regarding potential opportunities
(d) Submission of applications and negotiation of terms
(a) Identity
(b)Contact
(c) CV
(d) Marketing and communications
(e) Sensitive
(b)Contact
(c) CV
(d) Marketing and communications
(e) Sensitive
Necessary
for our legitimate interests (to provide recruitment services)
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 or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how clients and candidates use our services)
To
enable you to complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
Necessary
for our legitimate interests (to study how clients and candidates use our services,
to develop them and grow our business)
To
make suggestions and recommendations to you about services that may be of
interest to you, including providing details of job opportunities and potential
candidates
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
(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)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Service offers from us
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 services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if:
- you have requested information from us;
- you have purchased services from us; or
- we have collected your business contact information through legitimate channels and we believe that our services may be of interest to you.
You may opt out of receiving service offers from us at any time. If you opt out we will not send you any further communications regarding our services offers.
Third-party marketing
We do not share personal data with third parties for marketing purposes.
Opting out
You can ask us stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to other types of communications we may send you.
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.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table headed Purposes for which we will use your personal data above.
External Third Parties including:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
Candidate details will be shared with clients offering suitable job opportunities.
Client details will be shared with candidates where appropriate during the recruitment process.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
If we are asked to obtain a background search on a candidate by a client from a third party provider such as Kroll we will share information required by that third party service provider in order that the appropriate search may be carried out. Such searches are only undertaken by specific arrangement and after discussion with the candidate.
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.
6. International transfers
We use Microsoft to process and store personal data. This may result in your personal data being stored on Microsoft servers in countries outside of the EEA. We may also use a third party CRM system to process and store personal data which may result in personal data being stored on servers owned or controlled by the third party CRM system provider which are located in countries outside of the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We use Microsoft to process and store personal data. This may result in your personal data being stored on Microsoft servers in countries outside of the EEA. We may also use a third party CRM system to process and store personal data which may result in personal data being stored on servers owned or controlled by the third party CRM system provider which are located in countries outside of the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- your personal data is transferred to a country that has been deemed to provide an adequate level of protection for personal data by the European Commission;
- specific contracts approved by the European Commission have been used which give personal data the same protection it has in Europe;
- recipients of data in the US are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US; or
- you are a candidate and you have explicitly consented to our sending your personal data to a client outside of the EEA.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. 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.
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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances we will 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.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances we will 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can:
If you wish to exercise any of the rights set out above, please contact us.
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 could 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 could 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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Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
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 could 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 could 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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