Who we are:
Armstrong Wolfe Limited (Company Registration No. 07239221) is headquartered at 120 Eagle Tower, Montpellier Drive, Cheltenham, GL50 1TA.
What do we do as a firm?
Armstrong Wolfe engages in several human capital-related services and industry forums for its clients. This includes but is not limited to: executive search, executive interim, market research, industry forums and surveys.
The company gathers personal data to carry out these services to its clients. Personal information is stored, processed and transferred at various stages of these services both during and sometimes after client engagements are completed.
We are committed to engendering a culture of accountability, integrity and confidentiality regarding personal data and security in all aspects of the organisation.
Purpose of this policy:
The purpose of this policy is to confirm how Armstrong Wolfe uses your personal data. This policy has been amended in response to the General Data Protection Regulation that became enforceable in May 2018.
What does this policy cover?
The different types of data we collect about you
How and why we collect and use your personal data
How long we keep your personal data
What the legal basis for using your personal data is
When, how and why we share your personal data
What rights and choices you have when it comes to us using your personal data
How you can contact us
The data we collect about you:
We use your personal data to match your skills, experience and education with a potential employer. Initially we would collect basic information in relation to your name, contact details and role to share with a potential employer. Once we have your permission, we may gather and share more personal information from you in the form of a CV, compensation details and/or compensation expectations and references in assessing your suitability for a role.
We may also need to collect sensitive personal information about you that may include your nationality, visa status and other information relating to any background screening we are required to provide to future employers through our contractual obligations. We would only collect this information if you provide us with your consent to do so.
How do we collect your personal data?
We may collect personal data about you from the following sources:
From you directly
Publicly available sources
LinkedIn or other social networking sites
References: by word of mouth
If you are not already known to Armstrong Wolfe and we collect any of your personal data, we will let you know within 30 days of doing so. This will initially be via phone or email. If we collect any sensitive personal data (as outlined above), we require your explicit consent.
When signing up and/or registering on our website (armstrongwolfe.com), our newsletter or social media, you will need to provide the necessary details requested.
Why do we collect your personal data?
We collect personal data to enable us to match you to career opportunities we have been engaged to work on by our clients. This may be for a permanent, temporary or contracting opportunity or a consulting engagement. Collecting and exchanging personal data is an essential part of the process to assess your suitability for potential roles, to build market insight and meet client obligations. This is the legitimate interest as to why we collect and use your personal data.
How long do we keep your data for?
We will only keep your personal data for as long as we need it in order to fulfil our client obligations or our legal requirements.
We operate to the recommendation of the Association of Executive Search and Leadership Consultants (AESC) of holding data for six years. If there is no contact between yourself and Armstrong Wolfe in this time, all your personal data will be securely deleted.
Legal basis for holding your data:
The basis for holding your personal data is determined on one or more of the following reasons:
Legitimate interest (outlined above) and where we will ensure the data is accurate and we have been transparent with you
Armstrong Wolfe’s contractual obligations
Legal obligations under applicable law to retain records for a certain period
If you withdraw consent and request to be removed
Change in guidelines relating to data protection
Who do we share your personal data with?
We will only share your personal data with clients who have a contractual agreement with Armstrong Wolfe to hire a position that may be relevant to you. We have a global client base within Financial Services and the aligned Professional Services that serve this industry.
With your permission, we may be required to transfer your personal data outside the EAA for a suitable role opportunity with one of our clients. Privacy laws in these countries may be different to your home country. Where we do transfer your data to a country which has not been deemed to provide adequate data protection standards we always have security measures in place to protect your data.
To find out more, email firstname.lastname@example.org
Your basic personal data is also available to Armstrong Wolfe employees. Sensitive personal data is restricted to certain employees or with third party suppliers who we contract with to support processing of payroll, screening processes or with government agencies.
Armstrong Wolfe has a legitimate business interest in processing data to service its clients’ obligations. Processing would include, but not be restricted to: updating and keeping information accurate relating to: contact details; address; employment status; employers; roles; titles; compensation and a track record of correspondence through email, telephone conversations, face to face meetings or other communication. We recognise we have a requirement to ensure this data is accurate for the purposes of legitimate interest, contractual obligations and most importantly for your rights as an individual. Bank account data processing would only be incurred for those on the Armstrong Wolfe payroll for contracting purposes.
What are your rights?
By law you have certain rights available to you regarding your personal data. Further information is available from your country data regulator.
The right to be informed: you have the right to be provided with transparent, coherent information about how we use your data and your rights in relation to the use of your data. That is why we have provided this policy.
The right of access: you have the right to access your information (if we are processing it) and certain other information such as provided in this policy. This is so that you are aware and are able to check we are using it in accordance with data protection laws.
The right to rectification: you have the right to have your information corrected if it is inaccurate or incomplete.
The right to erasure: this enables you to request the deletion or removal of your information where there is no compelling reason for us to continue using it. There are exceptions to the right to erasure.
The right to restrict processing: you have the right to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We will keep a list of those who have asked for it to be restricted so that their request is respected.
The right to data portability: you have the right to transfer your personal data to another provider. You can move, copy and transfer data easily between our IT systems and their systems safely and securely without affecting its usability.
The right to object to processing: you have the right to object to certain types of processing, including processing for direct marketing, including for the purposes of potential opportunities.
The right to lodge a complaint: you have the right to make a complaint about the way we handle or process your data with your national data protection regulator.
The right to withdraw consent: if you have given 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). This includes your right to withdraw your consent with us for marketing purposes.
Access to your information:
You may request information about the personal data we hold. Subject access requests should be sent to email@example.com. Handling of these requests will be free of charge, but we may charge a reasonable fee if we receive repeated or excessive requests or further copies of the same information. We will respond within 30 days of you submitting the request.
Updates to this Policy:
We will keep this policy updated in response to changes in data privacy law and any changes to our business. Please review this policy for updates.
How do you contact us?
If you are unhappy with how we have handled your personal data, or have further questions on the processing of your personal data please contact us at: firstname.lastname@example.org