Lockwood Executive Search Ltd (“LWES”)
29 Farm Street London W1J 5RL
Company Registration Number: 09664616
Issue Date: 05 Jan 2021
Version Number: 3.01
Applicable Law: The Data Protection (Jersey) Law 2018 under which LOCKWOOD EXECUTIVE SEARCH is regulated in Jersey also known as (DJPL) and
the EU GDPR (EU) 2016/679 (General Data Protection Regulation) and UK General Data Protection Regulation (UK GDPR), tailored by the Data Protection Act 2018 in the UK.
The California Consumer Privacy Act of 2018 (CCPA) gives consumers more control over the personal information that businesses collect about them.
“The Data Protection (Jersey) Law 2018 and the Data Protection Authority (Jersey) Law 2018 both incorporate all the applicable elements of GDPR for Jersey, to ensure that Jersey has a level of protection equivalent to that of the European Union and has been passed as adequate please see link.”
Our clients can be from the UK, EU, Jersey and the US where we may be regulated by the above regulations.
At LOCKWOOD EXECUTIVE SEARCH, we regard your privacy as vitally important to our company and to you.
LOCKWOOD EXECUTIVE SEARCH may collect information about you via processing or interaction with you as a client during the normal business engagement as recruitment and placement company and directly or indirectly by email, phone or other means.
The information we collect may be personal data, if you agree to provide it, this personal data will allow us to contact you and send you information about our services and allow us to perform our services as per our contract and agreement under our engagement model.
- In providing us with your data, you hereby consent to us processing it for the purpose mentioned in this policy.
- We will not pass your personal data on to any third party without your express permission, except as defined herein for the provision of services that you have requested, other than authorities and the police in the event of any investigation or for legal reasons.
- Personal email addresses and phone numbers are not shared with any other entity other than our staff or partners to deliver the service unless you have explicitly chosen to do so.
For the purposes of the Data Protection;
- the data controller is Lockwood Executive Search Limited (“LOCKWOOD EXECUTIVE SEARCH”).
- LOCKWOOD EXECUTIVE SEARCH may use third-party processors to deliver specific services that are requested by you from LOCKWOOD EXECUTIVE SEARCH (see Processors below).
LOCKWOOD EXECUTIVE SEARCH are responsible for ensuring personal data collected is protected and handled under strict rules called ‘data protection principles’. We ensure the information is:
- used fairly, lawfully and transparently
- used for specified, explicit purposes
- used in a way that is adequate, relevant and limited to only what is necessary
- accurate and, where necessary, kept up to date
- kept for no longer than is necessary
- handled in a way that ensures appropriate security, including protection against unlawful or unauthorised processing, access, loss, destruction or damage
Information that we may collect from you
We may collect and/or process the following data about you:
- Information you provide to us - by filling in forms we send to you, or by entering into a contract with us, or by correspondence with us by email, letter, phone or other methods, data we collect from you that we might store data or any platform that we might administer containing your personal data, for you, which stores personal data, which includes data provided by you. By registering to use our services, or by subscribing to newsletters or sales notifications, or other information services, or by placing a request for recruitment or other related services, or otherwise contacting us.
- Personal data - The information you give us may include; your name, address, email address, IP address, and phone number, photos, addresses or anything which can identify an individual, which is subject to Data Protection.
- When do Lockwood Executive Search collect your data?
- register for a service or product that we supply by completing our ‘create your account’ form;
- update your account personal data details and contact Details; make placement requests, receive requests to discuss your role with potential employers, send emails or otherwise communicate with LOCKWOOD EXECUTIVE SEARCH.
- When do we otherwise collect your data?
- If you otherwise use the services without contract or engagement, we collect data from you:
- when you register with us, or inadvertently use our services without our knowledge, this would mean the customer has the relationship with you as a data subject.
- in monitoring your communications sent via our website, email, telephone and our service and use of a product we have developed to ensure and check compliance with the Terms and Conditions of Use or otherwise as required by law; and
- when you disclose your data to us through the website or otherwise through any other means.
- If you otherwise use the services without contract or engagement, we collect data from you:
- Data protection - all Personal data we hold is protected by us in accordance with the principles of the DATA PROTECTION LAWs above.
- Data security - We endeavour to take all reasonable steps to protect your data. All the data collected by us is stored on a secure platform in a secure hosting facility, and we take all reasonable steps to ensure all access is pre-authorised and recorded.
- Other information we collect about you - In accordance with our legal obligation to prevent fraudulent or abusive use of services, products and offerings, some data may be automatically collected and comprises the following:
- Technical information - such as your internet protocol (IP) address in our website logs, personal data supplied by you for your profile, time zone, browser type/version with plug-in types/versions, device information (operating system and platform);
- Information about your visit and use of our services, products and platforms - such as our/your Uniform Resource Locators (URL), including the date and time, information viewed/searched, site statistics, interaction (scrolling, clicks, mouse-overs), exit methods away from pages, phone numbers (if used to call our offices), the route to/from our site or from search engine links to our site including search engine address and search term used.
- Our website will not store any identifying information of your visit on your computer apart from a small text file called a cookie, which in itself does not contain any identifying information and does not mean that you entered the site. See the cookies policy link at the end of this document for more detail on cookies.
- Depending on the configuration of your browser, pages and images you view on our site may be stored on your computer. This feature, (which you can configure), is called caching.
- All information you exchange with the LOCKWOOD EXECUTIVE SEARCH website is accessible by its administrators and will only be used to prevent abuse, fraud and threats to members’ confidentiality or safety. This information will only be accessed with respect to specific reports of such activity.
- Information we receive from other sources - information about you may be received by us if you use another website or service that we operate or are connected within our normal course of business.
- Third-parties may also provide information to us about you, specifically from any of the following; our business partners and/or sub-contractors, or advertising and marketing services, or our technical and analytics providers, or our search engine and search information providers.
How your information is used
The information we hold about you is used as follows:
- Information that you provide to us - this information is used to meet our obligations within any contracts between you and us, and/or our legal obligations, and/or;
- to meet your requests for information and services, or
- to notify you of changes to our services, or make suggestions or recommendations that may interest you, or
- to improve the content of our site and ensure it is presented effectively for you and your device, or
- deal with investigations by the police or other regulatory bodies.
- Information that we collect about you - we use this information:
- to manage our website as well as for our efficient operations, which includes analysis, research, statistical and survey uses, together with testing and troubleshooting;
- to improve our website and content for users and their devices;
- to allow you to interact with our social media, website, products and services and take advantage of our online services, whenever you may elect to do so;
- to ensure our site is safe and secure by monitoring activities within the context of continual process improvement, which is a best practice requirement of the DATA PROTECTION LAWs above.
- to monitor advertising and marketing effectiveness for users, and/or to fine-tune advertising by relevance to users;
- to enable targeted suggestions/recommendations to users about services that may be of interest.
- Information we receive from other sources - we may use third-party information, which may be combined with information you provided to us and/or information collected by us, which may be used for the purposes we have defined above.
Know your rights
Under DATA PROTECTION (JERSEY) LAW 2018 all individuals, who are the owners of their Personal data, have specific and clear rights, which are;
|Right to Erasure||Every individual has the right to be forgotten upon request. The data controller must remove your Personal Data from its systems and request the same of any third-party systems of that controller unless other lawful requirements apply.|
|Right to Access||Every individual has the right to access their personal data held about them upon request.|
|Right to Portability||Every individual has the right to request their Personal data and use it for other parties they wish to engage with.|
|Right to be Informed||Every individual has the right to be informed about how their Personal Data is being used, which may be provided upon request of the individual, or before the controller changes any use of that data, giving the individual the right to consent or object.|
|Right to Objection||Every individual has the right to object to the use of their personal data for any purpose proposed by a controller.|
|Right to Rectification||Every individual has the right to have errors in their Personal data to be corrected.|
|Right to Restrict||Every individual has the right to restrict the uses of their Personal Data for any specific type of processing.|
|Rights on automated decisions & profiling||Every individual has the right to restrict or object to automated decision-making processes or profiling based on their Personal data.|
Right to complain to the authority
|You have the right to lodge a complaint with the authority: please email us first DPO@lockwoodes.comso we can attempt to resolve the issue, if it's not resolved to your satisfaction, then please contact the authority.
Jersey Office of the Information Commissioner
- Revoke your consent - in accordance with DATA PROTECTION LAWs above, to revoke consent for the processing of your Personal data send an email with the word “Revoke” in the subject field to DPO@lockwoodes.com
- Data Subject Access Request (DSAR) - in accordance with the DATA PROTECTION LAWs above,
- you may request us to send you details about any Personal data that we may hold about you, or
- you may request that we correct any errors, or
- you may request us to delete any/all personal data about you.
- DSAR Fee - In accordance with the DATA PROTECTION LAWs above, any DSAR is provided free of charge within 4 weeks, unless a particular DSAR is subject to other regulatory requirements as defined within the DATA PROTECTION LAWs above, in which case we will inform you as required by those specific regulations.
Please see the Jersey OIC process below as an example of how to to deal with a DSAR
The above diagram references: The right to access your personal information: https://jerseyoic.org/resource-room/the-right-to-access-your-personal-information/
Do we pass your information on to third parties?
We may pass your data to other parties as follows:
- Where relevant, we may pass your data to our employees, suppliers and agents to administer the website and the services provided to you by them or us, now or in the future.
- We may disclose your data to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence or suspected breach of the Terms and Conditions of Use and (where appropriate) Membership Terms and Conditions by you or otherwise where required by law.
We use the following third parties to process your data and deliver services for the purposes shown. All these processors have access to some of your Personal data as appropriate for the delivery of the purpose specified.
|Website, CRM and document management service providers||Maintenance and support of our Services offered, CRM and document management systems which allows access to and analysis of data.|
|Email Marketing for our services and products||Delivery of our email newsletters and Lockwood's marketing.|
|IT service providers||Maintenance and support of our IT systems.|
|Marketing and Event service providers||Marketing and Event Management services.|
Links to other sites
Please be aware that the LOCKWOOD EXECUTIVE SEARCH website, Services and products and/or marketing materials may link to other web sites or services, particularly in the cloud that may be accessed by you through our site or services or products that we develop.
We are not responsible for their data policies but a vigilant that all services we use observe good practice and will always do our best to select and use reputable systems, content or the security of these linked web sites. We do not have any control over the use to which third parties may have of your data, where you choose to purchase products or services or otherwise to contact them via our site.
Use of Social media
LOCKWOOD EXECUTIVE SEARCH is not responsible for content posted by third parties. LOCKWOOD EXECUTIVE SEARCH reserves the right, to the extent permitted under applicable law, to process, retain and monitor all electronic communications (including personal data).
By sending direct messages to Lockwood Executive Search and/or posting comments, you unequivocally consent to such processing, retention and monitoring. All posts, comments and messages are subject to the terms of this Policy.
Any views expressed via social media are those of the author alone and may differ from others within LOCKWOOD EXECUTIVE SEARCH.
Marketing to our contacts without their consent
We may hold business contact data about you if you are a professionally relevant contact for our services. Your data will only be used to inform you of a service or product which might be relevant to you in your professional capacity. Our main channel of communication is through email, and we conduct this marketing in adherence to the Privacy and Electronic Communications Regulation (PECR). This allows for business-to-business marketing on an opt-out basis in so long as a lawful means of processing under DATA PROTECTION LAWs above, has been established. Our lawful basis for processing in this instance is Legitimate Interests for international parties, or Contract for local members. We may also contact you by telephone from time to time to follow up on interest you have expressed or to verify contact information.
We will respect your wishes and how and if you want to be contacted. If you no longer wish to be contacted for marketing purposes, you can:
- Click the unsubscribe link in any email you are sent
- Call us on +44 (0) 1534 752 951
- Email DPO@lockwoodes.com
In accordance with the DATA PROTECTION LAWs above, (or similar/related regulations), we may require you to verify your identity prior to acting on any instruction. This measure is to protect you/your organisation from any potential abuse, and we will advise you accordingly, in compliance with the law and/or recognised best practice standards.
Transfer outside the EU/EEA
This site is accessible via the internet and therefore may potentially be accessed by anyone around the world. Other visitors may also access the site from outside Jersey, UK, USA and/or the European Economic Area.
- This means that, where you post your data on the site, this could be accessed from anywhere around the world and therefore a transfer of your data outside of Jersey and/or the European Economic Area may be deemed to have occurred.
- Data protection laws in countries outside of Jersey and/or the European Economic Area are generally not as protective.
By completing and publishing your member profile, you consent to such transfer of your data for and by way of the purpose stated here.
Data Retention Policy
User data is retained indefinitely to meet the legal obligations of LOCKWOOD EXECUTIVE SEARCH. However, we reserve the right to delete inactive user data older than ten years.
- E&OE: If you notice any errors (spelling, grammar or other) in this policy document, please feel free to notify us via our contact details below.
For any questions relating to your Personal Data, or to submit a DSAR, please contact us:
Lockwood Executive Search
29 Farm Street
London W1J 5RL
+44 (0) 203 923 6731
Phone: Call us on +44 (0) 1534 752 951