This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Your new rights under the GDPR are set out in this notice.
Who are we?
Company name: COGENT Executive Holdings Ltd (COGENT Executive)
Registered Address: 16-18 The Boscombe Centre, Mills Way, Amesbury, Salisbury, Wiltshire. SP4 7SD
London Office: Suite 58621, PO Box 6945, West End, London. W1A 6US
Company Number – 13084752
Telephone: 0204 526 6159
We provide Transition Management, Consultancy, Coaching & Mentoring, Advisory and Non-Executive Director services, including market mapping and individual assessment, to clients for their businesses.
What does this policy cover?
We at COGENT Executive take your personal data seriously. This policy:
- sets out the types of personal data that we collect about you
- explains how and why we collect and use your personal data
- explains how long we keep your personal data for
- explains when, why and with who we will share your personal data
- sets out the legal basis we have for using your personal data
- explains the effect of refusing to provide the personal data requested
- explains the different rights and choices you have when it comes to your personal data
- explains how we may contact you and how you can contact us.
What personal data do we collect about you?
To carry out our core Transition Management activities, we collect information about you which may include: your name, address and post code; private and corporate e-mail address and phone number; financial information and compliance documentation; references verifying your qualifications and experience and your right to work in the United Kingdom; curriculum vitae and photograph; employment details and preferences; links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, Facebook for Business or corporate website; commentary on discussions; documentation both in the public domain or shared with us for assignment purposes.
Where do we collect personal data about you from?
The following are the different sources we may collect personal data about you from:
- Directly from you. This is information you provide to us for the purposes of engaging with our services; searching for a new assignment opportunity and/or during the different assignment stages.
- From an agent/third party acting on your behalf. e.g. Executive Services Company; Group Company.
- By reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or associate.
- Through publicly available sources. For example but not limited to:
How and why do we use your personal data?
We use your personal data to match your professional abilities, experience and education with a potential client. We will initially collect basic information on you such as contact details and experience and pass this on to the client in search of assistance. If you are suitably qualified and interested in proceeding, we will, with your agreement, collect more information from you as you progress through the process e.g. to our assessment stage and then to client meeting stage.
We also use your personal data for the purposes of marketing our services.
How long do we keep your personal data for?
We retain different types of data for differing periods of time. The criteria we use to determine whether we should retain your personal data and how long for includes:
- The nature of the personal data
- Its perceived accuracy of your data
- Your engagement levels with our services
- Our legal obligations following an offer or when a placement has been made.
We may archive part or all of your personal data or retain it on our financial systems but delete all or part of it from our software system. On removal, we may anonymise parts of your data – particularly following a request for suppression or deletion of your data – to ensure we do not re-enter your personal data to our database unless you have requested us to do so.
Our current retention period for data on Executives who have not been placed on assignment, or are no longer showing any signs of engagement with our website, is 6 Years.
Who do we share your personal data with?
Your personal data is shared with the client who initiates a request for assistance, to ascertain whether you might be a solution for the assignment. We will inform you if/when this information would be supplied. We may also conduct checks on you to verify the information you have provided and where we do this we may share your information with Qualificationcheck.com and HEDD.ac.uk
What legal basis do we have for using your information?
For prospective executives, referees and clients, our processing is necessary for our Legitimate Interests, in that we need the information in order to be able to assess suitability for potential assignments, to find potential executives and to contact clients and referees.
We also have a Contractual and Legal basis to process and use your information when working directly with us.
Where we store your data
All information stored on our assignment software is secured through the Microsoft Azure Infrastructure and located at two data centres locations within Europe. Our primary centre is located in Microsoft’s Western European centre, and these facilities are secured by a series of measures, including (but not limited to) biometric access, security alarm systems and round-the-clock security staff. Additional security information on Microsoft’s data centres can be found here.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary or request that we stop processing your personal data, we may not be able to assess you for available assignments.
Do we transfer your data outside the EEA?
To better match your profile with current assignment opportunities we may transfer your personal data to clients and partners in countries outside the EEA. These countries’ privacy laws may be different from those in your home country. Where we transfer data to a country which has not been deemed to provide adequate data protection standards we will ensure, to the best of our ability, that security measures and approved model clauses are in place to protect your personal data.
The GDPR provides you with the following rights.:
- The right to be informed about the personal data we process on you
- The right of access to the personal data we process 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
- The right not to be subjected to automated decision-making and profiling.
Therefore, we encourage you to log in to your profile through our website to ensure your data is accurate, complete and up to date at all times.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
How will we contact you?
We may contact you by phone, email or social media. If you prefer a particular contact means over another, please advise accordingly.
How can you contact us?
If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact our Data Protection Officer here:
Address: Data Protection Officer, COGENT Executive, Upper Floor (C), 2 Mill Road, Salisbury, Wiltshire. SP2 7RZ Email: GDPR@cogentexecutive.com
Changes to our Privacy Notice
Any changes we make to our privacy notice in future will be posted on our website and, where appropriate, you will be notified by e-mail. Please check back frequently to view any updates or changes to our privacy notice or for any further information please email GDPR@cogentexecutive.com
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