This policy explains how we process personal data within our global businesses delivering search, consulting and assessment services.
Who we are
We are Horton Consulting Partnership LLP trading as Horton International UK, an international executive search Company. Further information can be found on the following websites:
Horton Consulting Partnership LLP (“we”, “us”) is committed to keeping your information secure and managing it in accordance with our legal responsibilities, under the privacy and data protection laws, as well as the General Data Protection Regulation (Regulation (EC) 2016/679 (“GDPR”) in the European Union (“EU”).
Who this policy applies to
We provide executive search services (“our services”) to our clients throughout the world. Details of our services can be found elsewhere on this website or those listed above. This policy applies to you whether you are a candidate for one of our clients, an individual we are assessing as an employee of one of our clients, a client, or whether you are a source or a referee in respect of a candidate or an employee of one of our clients.
For the purposes of this policy:
candidate(s) means an individual who is a candidate, applicant, potential candidate, employee of a client;
client(s) means any business, firm, organisation, government body or individual that mandates us to perform any of our services;
a referee is a person who provides a personal or work reference in respect of a candidate;
a source is a person who provides us with information or intelligence about a candidate.
Our clients expect that we identify the best individuals to fill roles within their organisations. We use research systems, online databases and other information sources, and talk to many individuals to identify potential candidates.
The nature of our work means we are required to process personal data quickly, confidentially and often without reference to the data subject. Accordingly, we process such data in accordance with the Data Protection Laws, regularly using our legitimate interest where it is not possible or feasible to speak directly with the data subject. We will seek consent before submitting a CV/resume to clients.
We collect information from candidates directly when we discuss opportunities on the telephone, via email, and directly submitted CVs.
This information includes your name, contact details, family details, CV, salary, qualifications, work history and career aspirations.
Where do we collect personal information from?
- Publicly available sources: e.g. LinkedIn, Google, research publications, company websites
- Directly from you: this is information you provide during telephone conversations and email/LinkedIn messaging exchanges and CVs
- By reference or word of mouth: e.g. you may be recommended by an acquaintance or former colleague
How we use your personal data
We use the personal data we collect from you for a number of purposes:
- Processing job applications, in partnership with our clients, on whose behalf we are instructed to help fill a job vacancy
- Searching for relevant candidates for confidential recruitment assignments where our client initially requests anonymity
- From time to time, we conduct mapping or research exercises on behalf of our clients. This is to enable them to understand a particular market
We will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others, or have your permission to do so.
Please be aware that we are not responsible for the data processing activities of others, such as our clients.
In providing our executive search services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests (carrying on the commercial activity of executive search services), which include:
- Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
- protecting our reputation
- maintaining a back-up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
- Using your personal data to:
- assess suitability and contact you regarding potential opportunities and/or our service
- collate market information or trends including providing analysis to potential or actual clients
- source potential opportunities or roles as part of our recruitment services
- personalise your experience and our offering, whether via our website or otherwise
This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes.
We will use client data to perform our services to you and other legitimate business purposes such as marketing.
Source and Referee
We will use source and referee data to perform our services, in particular, to enable us to obtain your opinions on a candidate.
We may also use this information to enable us to market our services to you as a potential client. We may, additionally, invite you to become a candidate in respect of the provision of our services.
The type of personal data we collect and process
In all cases, we collect and process personal data about you, including your name, address, telephone number and email address, salary details, references and job history.
If you proceed with a job application, or should we consult you about a role, you may be required to submit additional personal data, for example, a curriculum vitae (CV) or resume containing career/employment history, education, professional qualifications, memberships, details of papers written, references and referees, amongst other information.
Based on your explicit consent, we will also process any relevant psychometric assessments, psychological tests, or results from such assessments or tests.
We might also collect personal data from third-party databases and other public sources.
As well as basic contact information we will also collect information about your role and other information provided to us by your organisation.
Source and Referee
As well as basic contact information we will also collect information regarding your relationship/knowledge of a candidate and your opinions of that individual. We may obtain this information directly from you or publicly available information.
What we do:
For certain roles, we may run an advertisement to which you may respond, either electronically or via mail. Other roles may involve one of our researchers or consultants calling you to discuss the details.
Besides filling particular leadership vacancies, we also process personal data when we conduct market intelligence exercises to map out particular business sectors or functions to help clients understand the available talent.
For our commercial viability and to pursue these legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate for these purposes.
We will collect only the appropriate and essential data that is necessary for the purpose in question. The data collected may not be too excessive for the purposes they are collected. Principally, we will not collect sensitive data such as racial and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, sexual preferences, health, illness or disability to the personal data files of Horton International.
We encourage you not to provide us with sensitive personal data unless it is specifically requested, and we have your consent.
Your right to object and to have your data erased
You are not obliged to provide any personal data to us. However, please note that this may mean we will not be able to consider you in respect of any of our services.
Remember, you may withdraw any consent you have previously given, at any time. Also, you have the right to ask us to stop processing any personal data and to have it erased.
In these circumstances, we reserve the right to maintain basic personal data such as your name and address. This is to ensure your personal data is not processed by us in the future.
Please note that no automated decisions, such as computerised candidate profiling, are made on the basis of the information we collect.
Providing information to others
We work closely with trusted partners with whom we need to share personal data. These partners include:
- Other Horton offices around the world who comply with GDPR.
- Our clients, for whom we provide executive search services.
- Prospective clients, where we might need to demonstrate an understanding of a particular market and the individuals that work within it.
Where we share information with such a third party, you will not be contacted by them, unless we have obtained your prior consent.
Personal data collected by Horton International can be transferred to another European Economic Area member state (EU member countries and Iceland, Liechtenstein and Norway) in accordance with the same principles.
Keeping information secure
We endeavour to take every step to protect your data, using password protection, anti-virus software, Malware, cloud storage Encryption software and hosted data bases. However, no system can be 100% secure, and so we cannot be held responsible for unauthorised or unintended access that is beyond our reasonable control.
Information about others
Keeping your records
We keep your personal data for as long as required to provide our services, and in accordance with legal, tax and accounting requirements. Where your personal data is no longer required, we will ensure it is disposed of in a secure manner.
You have the right to request copies of your personal data held by Horton International UK. If you think any of that data is inaccurate, you may also ask us to correct it. You also have the right to require us to stop processing your personal data.
To get in touch with us about any of this, please email or write to us at the address below. Please note that we may request proof of identity. We will respond to your requests within the required time frame.
You may withdraw your consent to our processing of your personal information for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter, where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.
Horton International will only transfer your personal data to its executive search assignment clients and consultancy companies who perform assignments for Horton.
Horton engages subcontractors to perform parts of the service, such as companies performing candidate testing services. They may have access to personal data so that they can perform their duties but only to the extent required for their performance.
We may also provide access to information to our affiliated companies and other parties belonging to Horton Group of companies globally.
When transferring personal data to third parties, Horton International always agrees in a separate written agreement the rights and obligations of the service provider in accordance with the applicable laws.
Horton Consulting Partnership LLP
13 Upper High Street