1. What is the purpose of this document?
Mind Partners (‘We’ or ‘Us’) take the management of the personal data (“data” or “information”) of each candidate (‘You’) seriously and endeavour to treat them with the utmost care. The purpose of this Privacy Policy (“Policy”) is to clearly lay out our Privacy Notice for candidates’ data as we are a ‘controller’ in relation to these data.
This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work through Mind Partners. It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the UK General Data Protection Regulation (UK GDPR).
We will comply with data protection law and principles, which means that your data will be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.
2. How is this document organised?
This page is organised so as to give you direct access to the sections you wish to read by clicking on the links in the menu above.
3. Who are we?
We are an executive search firm. We provide our clients with recruitment and search services for permanent and temporary positions. We also provide recruitment consulting services.
Within the framework of our activity, we are led to communicate with candidates about positions for which our clients recruit.
Please find below legal information about us:
Website’s editor
Mind Partners LLP
Registered company number OC423545 for England and Wales
VAT number: 314805911
Head office: 47-48 Russell Square – London WC1B 4JP
Phone: +44 (0) 207 554 0736
Head of publication: Valeryane ELPHICK
ICO registration number: ZB309481
Website host
OVH
SAS with a capital of 10,000,000.00€
RCS Roubaix – Tourcoing 424 761 419 00045
VAT number: FR22 424 761 419
Head office: 2 rue Kellermann – 59100 Roubaix – France
4. What personal data do we collect?
Personal data mean « any information relating to an identified or identifiable individual ». This does not include data from which the identity has been removed (anonymous data).
Our mission is to identify and select candidates who match our clients’ recruitment criteria.
We collect, process, use and transfer data as required, within the limits as detailed in this Privacy Notice, to ensure that candidates are suitable for the positions we are working on.
Following the collection of information, we process your personal data in order to establish the relevance of each application during the recruitment process.
This personal data may include, but is not limited to:
o your CV;
o your contact details (title, first name, surname, address, telephone number, email);
o your educational records;
o your work experience;
o information about your job search: your current and/or previous salary and salary expectations, the position you are looking for;
o the references you give us;
o and any other information needed to support you in the recruitment process, such as proof of your eligibility to work in the UK, which could include a copy of your passport, a copy of a work visa, your nationality, your place of birth, a driving licence, etc..;
If you do not wish to communicate your personal data as indicated in this Policy, we will not be able to process your application.
5. Who is responsible for the collection of personal data?
The entity responsible for the processing of personal data is Mind Partners, whose legal representative is Ms. Valeryane ELPHICK.
Mind Partners commits itself to respect the framework of the legal provisions in force and to never sell your personal data to anyone.
6. Where do we collect personal data about you?
We collect your personal data:
o when you apply on partners’ job boards;
o on social networks and other sources of public information;
o during interviews with you;
o by reference or word of mouth (e.g., from a friend, a previous employer, a colleague);
o if you have been named as a referee, a candidate has provided us with your personal details.
7. How long do we keep your personal data?
Your data will be retained for a period of up to TWO (2) years after our last contact with you. At the end of this period, you will be contacted again, and you can decide whether you wish for your personal data to continue to be stored in our database.
In any case, your personal data will be stored in accordance with the framework of the legal provisions in force.
8. Who has access to your personal data?
Mind Partners is involved in the collection, processing, use and transfer of your data.
Other parties will have access to your personal data:
o our clients will have access to your personal data to determine the extent to which your profile corresponds to the position they recruit for;
o our data storage providers who manage our databases. These suppliers and data storage providers are located in the EEA and are subject to the same regulations as Mind Partners;
o our affiliated partners who are involved in recruitment on behalf of clients and who work with the same requirements and for the same recruitment purposes as we do.
We also inform you that we may, after you have given us explicit permission, carry out checks on your personal data.
9. What is the purpose of the data that we collect?
We may collect, process, use and transfer all or part of the data:
o in order to carry out our recruitment mission on behalf of our clients. We collect personal data in order to qualify candidates for the position entrusted by our client. Once processed, the personal data of successful candidates is transferred to the client so that the client can finalise their recruitment;
o in order to contact you to exchange information on the state of the job market and/or to offer you professional opportunities matching your profile;
We do not sell your personal data, which is only used for our recruitment services.
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
10. What rights do you have in relation to your personal data held by us?
In accordance with the applicable regulations in force, our candidates have the following rights:
o Right to be informed: you have the right to be provided with clear and easily understandable information about how we use your data. This information is detailed in this Policy.
o Right of access to your data (article 15 GDPR);
o Right to rectification (article 16 GDPR), updating and completion of your data;
o Right to deletion of your data (article 17 GDPR): this enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing;
o Right to withdraw consent (Article 13-2c GDPR): if you have given us your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful);
o Right to restrict the processing of your data (Article 18 GDPR): you have rights to “block” or suppress further use of your information;
o Right to object to the processing of data (Article 21 GDPR): where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
o Right to the portability of your data, when these data are subject to automatic processing based on your consent or on a contract (Article 20 GDPR);
o Right to determine the fate of your data after your death and to choose to whom we shall communicate (or not) your data to a third party you have previously designated. As soon as we become aware of a candidate’s death and in the absence of instructions from him or her, we undertake to destroy his or her data, unless its retention proves necessary for evidentiary purposes or to meet a legal obligation;
o Right to lodge a complaint: you have the right to lodge a complaint about the way we collect, use, process or transfer your personal data with your national data protection regulator, the Information Commissioner’s Office (ICO) who is responsible for data protection issues in the UK.
If you would like to know how we use your personal data, request a correction or object to their processing, or if you have any questions about this privacy notice or how we handle your data, please contact us in writing:
o by sending an email to: contact@mindpartners.uk
o at the following postal address
Mind Partners – Data Protection Officer, Mind Partners LLP
180-186 Kings Cross Road, London WC1X 9DE
In this case, you must indicate the personal data you would like us to correct, update or delete, identifying yourself precisely with a copy of an identity document (identity card or passport).
Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request.
11. Non-disclosure of your personal data
We do not collect, process, use or transfer your data to a country outside the EEA or recognised as « unsuitable » by the European Commission without prior notice to the candidate.
However, we remain free to choose our technical and commercial subcontractors provided that they present sufficient guarantees with regards to the requirements of the General Data Protection Regulation (GDPR: n° 2016-679).
We undertake to take all necessary precautions to preserve the security of the data and in particular that it is not communicated to unauthorised persons.
However, if an incident affecting the integrity or confidentiality of your data is brought to our attention, we must inform you as soon as possible of the corrective measures taken.
In addition, we do not collect « sensitive data » such as a candidate’s date of birth, religion, political affiliation, sexual orientation or civil status and you will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Your data may be processed by our partners and subcontractors as detailed in paragraph 8, and this solely in order to achieve the purposes of the recruitment mission of a recruitment agency such as Mind Partners.
12. Notification in case of incident
If we were to notice a security breach, we would immediately warn the candidates concerned to allow them to take appropriate action. Our incident notification procedures take into account our legal responsibilities, both at national and European levels.
We are strongly committed to keeping our clients fully aware of all issues concerning the security of their accounts and to giving them all necessary information to help them meet their own regulatory reporting responsibilities.
No candidates’ personal information is released, traded, transferred, assigned or sold in any way without them knowing.
Only the assumption of the repurchase of Mind Partners and its rights would allow the transmission of the said information to the possible buyer, who would be, in turn, held to the same obligation of conservation and modification of the candidates’ data.
13. Security
To guarantee the security and privacy of personal data, Mind Partners uses networks which are protected by standard devices such as firewalls, pseudonymisation, encryption and passwords.
While processing personal data, Mind Partners takes all the necessary measures to protect them against any loss, abusive use, unauthorised access, disclosure, alteration or destruction.
14. Changes to this Privacy Notice
We keep this Privacy Notice under regular review. This version was last updated on 07 March 2022.
This Privacy Notice does not override any applicable national data privacy laws and regulations in countries where we operate.