Privacy Policy
Warren Partners is committed to ensuring that the privacy of our clients and candidates is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this Privacy Policy.
1. WHO WE ARE
Warren Partners (referred to in this policy as “we”, “us” or “our”)
Spaces, 125 Deansgate
Manchester
M3 2BY
ICO Registration Number: Z5647989
For all data protection concerns or queries, please contact the Data Protection Leads at gdpr@warrenpartners.co.uk who will be able to assist further.
Data Protection Leads:
Stephanie Clarke – Head of Research Operations
Sophie Radcliffe – Head of Communications and Strategic Projects
2. PERSONAL INFORMATION WE COLLECT ABOUT YOU
Dependent on the nature of your relationship with Warren Partners, your personal data will be processed in a variety of ways.
We will collect, use, store and transfer different kinds of personal information about you which we have grouped together in the table below.
| Categories of personal information | Description |
| Identity details | First name, middle names, last name, nickname, driving license, date of birth, national insurance number, passport, birth certificate, signature, nationality, image. |
| Contact details | Telephone number(s), email address(es), postal address(es), work address(es). |
| Candidate details | CV, work history, references, psychometric testing report results, previous job descriptions, previous salaries, company performance, press coverage, attachments supplied. |
| Education details | School/College/Universities attended; qualifications achieved. |
| Equal opportunity details | Diversity indicator, gender, racial or ethnic origin, sexual orientation, religious and philosophical beliefs. |
| Professional details | Remuneration information, role profile, business information, organisation charts, board profiles, board dates, start date. |
| Health details | Medical history, mental health details, disability details, all information concerning an individual’s health. |
| Lifestyle details | Family details, details surrounding personal life, marital status, details of dependents. |
| Communication details | Feedback, questions, notes, any information that is contained within a message body or a subject from an individual. |
| Technical details | IP address, browser type, cookies. |
3. HOW WE COLLECT YOUR PERSONAL INFORMATION
Based on your interactions with us, we will collect your personal information in the following ways:
- When you register your interest or request to use our services;
- When you talk with us either over the phone, via post or through email or text;
- When we review publicly available sources (e.g. including regulatory registers, the internet);
- When we collect your personal data through BoardEx;
- When we collate details surrounding the market and prospective candidates that would be applicable for a highlighted position or potential future opportunities;
- When you visit our website; and
- When you fill out our forms or provide us with feedback.
Please note, failure to provide required personal information may negatively affect our ability to carry out core business tasks that may benefit you.
4. HOW WE USE YOUR PERSONAL INFORMATION
We are only allowed to use your personal information if we have a legal basis to do so, and we are required to inform you of what that legal basis is. We have set out in the table below: the purposes for processing your information, the categories of personal information affected, and the legal basis on which we rely when we process your personal information.
In some circumstances we can use your personal information if it is in our legitimate interest to do so, provided that we have told you what that legitimate interest is. A legitimate interest is when we have a business or commercial reason to use your information which, when balanced against your rights, is justifiable. If we are relying on our legitimate interests, we have set that out in the table below.
| Purposes for processing | Categories of personal information | Legal basis for processing | Legitimate Interests (if applicable) |
| To administer aptitude, personality and psychometric testing to candidates. | · Identity
· Contact · Communication |
· Consent
· Performance of a Contract |
N/A |
| To manage our relationship with clients and candidates, including notifying you about changes to our terms or privacy notices. | · Identity
· Contact · Candidate · Equal Opportunity · Profession · Education · Health |
· Performance of a Contract
· Legal Obligation · Legitimate Interest |
To keep our records up to date and liaise with you regarding your status within the executive search process. |
| To contact references provided by candidates and other individuals of interest to supply a reference. | · Identity
· Contact · Profession · Communication |
· Performance of a Contract
· Legitimate Interest |
To ensure that appropriate due diligence is performed on a candidate. |
| To conduct an executive search on behalf of clients to fill a designated role. | · Identity
· Contact · Candidate · Equal Opportunity · Profession · Education · Health · Lifestyle |
· Performance of a Contract | N/A |
| To provide guidance and support to clients. | · Identity
· Contact · Candidate · Profession · Communication |
· Performance of a Contract | N/A |
| To assess a candidate’s suitability for a role. | · Identity
· Contact · Candidate · Equal Opportunity · Profession · Education · Health · Lifestyle |
· Performance of a Contract | N/A |
| To generate reports which include progress reports, longlist reports, shortlist reports, individual candidate assessment reports, psychometric reports. | · Identity
· Contact · Candidate · Equal Opportunity · Profession · Education · Health · Lifestyle |
· Performance of a Contract
· Legitimate Interest · Consent |
To determine a candidate’s suitability for the role. |
| To keep you informed of our services and administer marketing. | · Identity
· Contact · Profession · Equal Opportunity |
· Consent
· Legitimate Interests |
For postal mail, to administer marketing. |
| To conduct research into the market including conducting market mapping and providing information to the client of a concept candidate. | · Identity
· Contact · Candidate · Equal Opportunity · Profession |
· Legitimate Interests | To demonstrate the company’s awareness of the market and to meet the client’s needs.
|
| To manage incoming general enquiries or complaints from candidates and clients. | · Identity
· Contact · Communication · Technical |
· Legitimate Interests | To ensure that enquiries and complaints are managed appropriately. |
| To conduct sourcing and searches for the desired candidate and contact relevant individuals to pass on candidate opportunities to their network. | · Identity
· Contact · Equal Opportunity · Profession · Communication · Candidate |
· Legitimate Interests | To increase the reach for a candidate position and ensure that the appropriate candidate is selected for the role. |
| To gather feedback from clients and candidates. | · Identity
· Contact · Communication |
· Legitimate Interests | To ensure that stakeholder opinions are considered. |
| To administer and manage the website. | · Identity
· Technical |
· Legitimate Interests
· Consent |
To ensure that the website is secure and is fit for purpose. |
5. SPECIAL CATEGORY DATA
Special category data is personal information that is more sensitive by its nature such as racial and ethnic origin. Throughout the search process, there will be circumstances where your special category data is required to be processed to ensure the processing is fair.
Our special category condition for processing equal opportunity details is Substantial Public Interest Conditions Article 9 (2)(g) of the UK General Data Protection Regulation (UK GDPR):
- Equality of Opportunity or Treatment; and
- Racial and Ethnic Diversity at Senior Levels.
Our special category condition for processing your health details is Health or Social Care – Article 9 (2)(h) of the UK GDPR.
6. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
In order to administer our services and meet our legal obligations, we only share your personal information with third parties in the following circumstances:
- To administer marketing;
- To administer and manage events;
- To manage and monitor your relationship with us through our CRM;
- To obtain candidate information and map relationships and intelligence;
- To conduct personality and psychometric testing;
- To administer our telephone system;
- To receive IT support where required;
- To administer our website;
- To administer candidate and client feedback; and
- To meet legal obligations, for example, for the purposes of national security, taxation and criminal investigations.
Personal data that is publicly available may be shared with clients as part of providing a concept candidate or to conduct market mapping.
Where we share your personal data that you have provided to us with a client, we will request your permission to do so.
Before we share your personal information with a third-party, we will ensure that there is an appropriate Data Processing or Data Sharing Agreement in place to protect the sharing of the information.
We will never make your personal information available to anyone outside Warren Partners for them to use for their own marketing purposes without your prior consent.
7. TRANSFERRING YOUR PERSONAL INFORMATION OUTSIDE OF THE EEA
The European Economic Area (EEA) consists of the EU Member States, Iceland, Liechtenstein and Norway. If we transfer your personal information outside of the EEA, we must tell you and we will rely on one of the following:
- Adequacy Decision: The country we send your personal information to provides an adequate level of protection which has been approved by the European Commission.
- Standard Contractual Clauses: The recipient of your personal information has provided us with signed Standard Contractual Clauses which has been approved by the European Commission. This holds the recipient accountable to safeguard the personal information.
- International Data Transfer Agreement / Addendum (IDTA): The recipient of your personal information has provided us with a signed IDTA which has been approved by the Information Commissioners Office (ICO). This holds the recipient accountable to safeguard the personal information.
Circumstances where your personal information may be transferred outside of the EEA are as follows:
| Purpose of processing | Categories of personal information | Third-party | Location | Safeguard |
| For the administration of marketing. | · Identity
· Contact · Job · Equal Opportunity |
MailChimp | United States | SCC’s |
| For the administration of marketing. | · Identity
· Contact · Job · Equal Opportunity |
Campaign Monitor | United States | SCC’s |
8. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We will keep your personal information for as long as necessary to allow us to carry out our business functions. This includes satisfying any legal, accounting, or reporting requirements. When we assess how long to retain your personal information, we will consider the following:
- Any statutory or legal obligations;
- The terms we have enclosed in contracts or agreements we have with yourself;
- The purposes for which we originally collected the personal information;
- The lawful grounds on which we based our processing;
- The types of personal information we have collected;
- The amount and categories of your personal information; and
- Whether the purpose of the processing could reasonably be fulfilled by other means.
Warren Partners regularly review the retention of your personal information held within our care to ensure that we are not keeping your personal information for longer than is necessary.
9. HOW WE LOOK AFTER YOUR PERSONAL INFORMATION
We will protect your personal information that you have provided to us via appropriate security measures and controls. This includes implementing technical and organisational measures to prevent the loss, misuse or alteration of your personal information.
Warren Partners limits access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instruction, and they are subject to a duty of confidentiality.
10. YOUR RIGHTS
Everyone in the scope of the UK GDPR has rights relating to the collection and use of their personal information. The rights that apply to your personal information that is held within Warren Partners are listed below:
- Right to be Informed: We will always be transparent in the way we use your personal information. You will be informed about the processing through relevant Privacy Policies.
- Right to Access: You have a right to request access to the personal information that we hold about you.
- Right to Rectification: We want to make sure that the personal information we hold about you is accurate and up to date. If any of your details are incorrect, please let us know and we will amend them.
- Right to Erasure: You have the right to have your information ‘erased’ in the following situations:
- Where the personal information is no longer necessary in relation to the purpose for which it was originally collected or processed;
- When you withdraw consent;
- When you object to the processing and there is no overriding legitimate interest for continuing the processing;
- When the personal information was unlawfully processed; or
- When the personal information has to be erased in order to comply with a legal obligation.
Please note that each request will be reviewed on a case-by-case basis and where we have a lawful reason to retain the information or where exceptions exist within our retention policy, then it may not be erased.
- Right to Restrict Processing: You have the right to restrict processing in the following situations:
- Where you contest the accuracy of your personal information, we will restrict the processing until you have verified the accuracy of your personal information;
- When processing is unlawful, and you oppose erasure and request restriction instead; or
- Where we no longer need the personal information, but you require the information to establish, exercise or defend a legal claim.
- Right to Data Portability: In certain situations, you have the right to obtain and reuse your personal information for your own purposes via a machine-readable format, such as a .CSV file.
- Right to Object: You have the right to object to the processing of your personal information in the following circumstances:
- You no longer want to receive direct marketing; or
- Where processing is based on our legitimate interests.
- Rights in relation to automated decision-making including profiling: You have rights in relation to solely automatic decisions that are made about yourself. If we are making solely automated decisions about yourself, we will ensure that:
- You are informed of the processing (either through this Privacy Policy or separately);
- You are provided with a simple way to request human intervention or challenge a decision that has been made about yourself; and
- We carry out regular checks to make sure that the systems that conduct these decisions are working as intended.
If you want to exercise any of your rights listed above, please contact us.
11. NOT HAPPY?
If you feel that Warren Partners have not upheld your rights, we ask that you contact us by emailing the Data Protection Leads.
If you are not satisfied with our response, or believe that we are not processing your personal information in accordance with the law, you have the right to lodge a complaint with the Information Commissioners Office (ICO) by using the details below. We would be grateful for the opportunity to manage your concerns directly before you approach the ICO so please contact us in the first instance.
Address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: https://ico.org.uk/make-a-complaint/
12. DEFINITIONS
- Data Protection Leads refers to the individuals responsible for the management of data protection compliance within Warren Partners.
- Data subject means an individual who can be identified by personal data.
- Legal basis means a lawful reason that we have to process personal data.
- Personal data means any information relating to an identified or identifiable natural person (‘data subject’).
- Processing means any operation or set of operations which is performed on personal information or on sets of personal information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
- Special Category Personal Data is data relating to the racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation of the data subject.
- Supervisory Authority means an independent public authority which is established by a Member State.
- Third-party means a natural or legal person, public authority, agency or body other than the data subject, under our direct authority.