Privacy Policy – SEBA International
We ask that you read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
Who we are
SEBA International is a global executive search organisation with highly specialized expertise in the Financial Stability and Go To Market disciplines. A list of our offices, relevant legal entities and contact details is set at the end of this policy. When we refer to SEBA International ("SEBA", "we", "us", "our") we mean those legal entities that are part of our group and which are listed at the end of this policy.
SEBA aims to comply with best practice and applicable privacy laws including the General Data Protection Regulation (GDPR) to the extent applicable to us. This policy applies to those of our legal entities who are data controllers (controllers) for the purpose of applicable privacy laws.
The personal information we collect and use
Information collected by us from you
The personal information we collect depends on our relationship with you – for example you may be an actual or prospective client or a candidate.
Where you are a client or prospective client ("client") we typically collect personal information relating to how we contact and liaise with you in relation to the services we provide your organisation and the placing of candidates. So for example you may have given us the name of contacts within your organisation and their contact details including job titles, addresses (post and/or email) and telephone numbers. We may also have been provided with information about your preferences in terms of receiving information from us and the candidates and services you require.
Where you are a candidate you may have given us your career history, CV, contact details, date of birth and other information relevant to you and your career and positions that might interest you. This may be through an email exchange with us or a conversation with us. As your engagement with us and the client deepens we may collect further more specific personal information from you at that time depending on what the client requires and in consultation with you.
We may also collect information from you where you provide a reference in relation to a candidate or other information relating to a candidate – this will include your contact details and any other information you may provide us with.
Use of our website
We seek to minimize any personal data we may collect via our website (e.g. IP addresses) to the extent necessary for us to provide the site to you.
Our website also uses cookies – please see our Cookie Policy.
Information collected from other sources
As an executive search firm our clients expect us to identify the best candidates and we may obtain job-related personal information about candidates from a variety of sources in addition to the candidate themselves e.g. through recommendation or from information available in the public domain including LinkedIn.
We may also obtain details about our clients from various sources including company databases and registries.
How we use your personal information
Where you are a client we use your personal information to liaise with you about your search requirements and the sourcing of candidates as well as keeping you updated on industry developments (for example whitepapers) and candidates that may be of interest.
Where you are a candidate we use your information to provide services to you, to communicate with you about opportunities that may be of interest to you, to provide career guidance and market/industry updates (for example whitepapers) and with your consent to provide your CV and other related information to our clients as well as to take forward any interviews our hiring process initiated by our clients.
Who we share your personal information with
If you are a candidate we will share your personal information with our clients with your consent.
Our IT suppliers may have access to your personal information where necessary but this is strictly under our control and we apply appropriate security measures to any processing they may carry out for us.
We share your personal information within our group and with our partners, employees and consultants.
We may share your personal information with third parties in connection with any investment in, or sale or transfer of our business, assets or group companies, or a merger, or group reorganisation.
We will not share your personal information with any other third party unless we are required by law to do so, where you agree we may do so, or where we need to do so to be able to enforce our legal rights.
Whether information has to be provided by you, and if so why
The provision of certain information from you is required in order for us to keep you updated on opportunities, provide guidance and with your permission in order to offer you as a candidate to our clients who are looking for suitable candidates. If you do not provide us this information we will not be able to provide the services requested or progress any potential hiring. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
How long your personal information will be kept
We only keep your information for as long as we need to do so in order to provide and market our services to you (as described above) or otherwise for as long as reasonably required in relation to the purposes for which it was supplied or to comply with our legal obligations (for example in relation to tax or accounting). We may retain some of your information beyond this period for example in relation to pursuing or defending any actual or potential legal claims. Once no longer needed we will securely erase your personal information.
Reasons we can collect and use your personal information
We rely on the following lawful reasons to collect and use your personal data and on occasion more than one lawful basis may apply to the processing:
- to perform or enter into any contract with you or the organization you represent (if a client)
- our legitimate interests in providing search services to candidates and clients. The exchange of personal information relating to candidates and client contacts is essential and in our legitimate interests in order for us to carry on our business, support our candidates' career aspirations and provide appropriate search services to our clients to assist them in their business endeavours. In determining what personal information we collect and share for our legitimate interests we carefully consider and balance our legitimate interests against your privacy interests
- to comply with our legal obligations
- to protect your vital interests or that of another person (e.g. in an emergency)
- where you consent to the processing where we ask you to (e.g. for certain sorts of marketing or other processing where the law requires this)
Transfer of your information across international borders
We operate globally so we may transfer your personal information (a) within our group (whose address details are noted at the end of this policy) where we need to do so and (b) (with your permission) to our clients who are located globally. Where we transfer your personal data within our group from within the EEA to outside of the EEA we do so in accordance with the relevant regulatory requirements by using EU-approved data transfer provisions/clauses (Article 46 GDPR) and we are happy to provide more information on request (contact details below). Our IT provider is in the USA.
Your rights
We take your privacy seriously and this is why we set out in this policy how we process your personal information as you have the right to know this. In addition if you would like us to erase or correct your personal information, to give you access to the personal information we may hold on you, you wish to object to our processing, or you wish to unsubscribe from any marketing please let us know – we will comply with such requests in accordance with our legal obligations.
In addition you may also have rights under the General Data Protection Regulation which include the rights listed above. For further information on such rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us (contact details below) and let us have enough information to identify you;
- let us have proof of your identity and address on request, and
- let us know the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
Please be aware that sending information over the internet is generally not typically secure so any data you send is sent at your own risk.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also may also give you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
Changes to this privacy notice
This privacy notice was published on 5 August 2018
We may change this privacy notice from time to time, when we do we will inform you via email or by posting the updated notice on our website.
How to contact us in relation to data privacy
Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us please send an email to data@sebasearch.com or contact SEBA INTERNATIONAL, LLC (address details below).
Details of our group legal entities and places of business
USA:
SEBA INTERNATIONAL, LLC
120 BROADWAY, SUITE 2720, NEW YORK, NY 10271;
71 STEVENSON STREET, SUITE 400, SAN FRANCISCO, CA 94105
UK:
SEBA INTERNATIONAL LTD
1st FLOOR, 3 MORE LONDON RIVERSIDE, LONDON SE1 2RE