This Data Protection Policy governs FDU Group Limited’s processing of all personal data provided to us via the fdu website, submitted to us by email, over the phone or through other means. Please read it carefully.
1. Who we are and how we manage your personal data
FDU Group Limited, trading as fdu, is registered as a data controller in the United Kingdom for the purposes of the EU GDPR. We ensure that the data you supply to us is processed fairly and lawfully, with skill, due care and attention and used only for the purposes set out in this policy.
2. How we receive information and how we may use it
- Directly from you: This is information you provide while searching for a new opportunity and/or during the different recruitment stages.
- From an agent/third party acting on your behalf: For example, Interim Management Company.
- Through publicly available sources: For example, we use the following public sources:
- By reference or word of mouth: For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer.
- Direct application. When you apply directly to become a Candidate for whom we can facilitate a role search or via a third party when you respond to a job post placed by fdu on a job board on behalf of a third-party Client.
This statement explains how we process personal data received into our organisation. When you register with fdu you MUST consent to us collecting and storing your personal information. You will not be able to submit your enquiry or details to fdu without consenting to us storing your personal data. This may include but is not restricted to your name; contact details; address; employment history; mobility and education.
During telephone conversations and face to face interviews with regard to employment preferences, strengths and work experience may be stored on your personal record. This information facilitates our ability to support your job search and to provide a basis for recommendation when short-listing Candidates for a particular role. By explicitly providing consent when you register with fdu, you are providing permission for our storage of this information. fdu will never share personal information or a Curriculum Vitae with a third party without your explicit consent.
Due to the nature of executive search and finance recruitment, a significant number of Candidates reconnect with our organisation periodically. It is not uncommon for this to occur years after we have placed them in a role. For this reason, your consent includes explicit consent to retain your personal details until such time as you wish us to delete your records from our database or refrain from further engagement.
If you do not consent to fdu storing your personal data or setting up a personal registration for you, please do not submit your Curriculum Vitae for any roles advertised by fdu. We are unable to process your application without receipt of consent to process and store your personal information.
How do we use your personal data?
We use your personal data to match your skills, experience and education with a potential employer. We will initially collect basic information on you such as contact details, job role and experience and then pass this on to the Client in search of personnel. If you are chosen by the Client and go through to the next stage we will then be collecting more information from you at the interview (or equivalent) stage and onwards in that manner.
How long do we keep your personal data for?
We only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
When determining the relevant retention periods, we will take into account factors including:
- our contractual obligations and rights in relation to the information involved;
- legal obligation(s) under applicable law to retain data for a certain period of time;
- our legitimate interest where we have carried out a balancing test (see legal basis below);
- statute of limitations under applicable law(s);
- (potential) disputes;
- if you have made a request to have your information deleted; and
- guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information once this is no longer needed.
With whom do we share your personal data?
We share your personal data with the Client who has a position to fill, in order to determine with the Client whether you are a good fit for the available position. We may also conduct checks on you to verify the information you have provided. Where this is necessary you will be advised accordingly.
What legal basis do we have for using your information?
For prospective Candidates, interim managers, referees and Clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles, to find potential Candidates and to contact Clients and referees.
If you are shortlisted as a Candidate then this may involve the processing of more detailed personal data including sensitive data that you or others provide about you. In that case, we always ask for your consent before undertaking such processing.
3. Job Alerts
We may on occasion contact Candidates stored in our database who are not actively looking for a new role. When you apply for a job or register using our website you will be asked to tick a box indicating that you consent to us storing the personal data you have provided. By providing consent to our storage of your personal data you are also providing consent to us contacting you if we receive details of a role which specifically matches your career aspirations. We will only do this where you, the potential Candidate, meet a detailed brief provided by one of our Clients, and where you have provided explicit consent to us storing and using your data.
4. Our Promise to Candidates
We will never share Candidate personal details or Curriculum Vitaes with a third party without the Candidate’s explicit consent, and then we will only share the personal information with that one company or individual.
5. Contacting Recruitment Consultants directly
If you contact one of our Recruitment Consultants directly and request they consult with you regarding your job search, or regarding a particular job role, you are giving your consent to fdu processing your email and the data contained within your email for lawful purposes, as per Clauses 2 and 3 above.
By sending an updated Curriculum Vitae directly to one of our Recruitment Consultants you are giving consent to fdu processing and storing that information, as per Clauses 2 and 3 above. As referred to in Clause 4 of our privacy notice, we will not share your information with any third party without your explicit consent.
6. Client Contacts and other third parties involved in the marketing and supply of resourcing services
Contacts are an important part of our marketing process and recruitment placement services and so we acquire data about these individuals. We collect data for “specified, explicit, and legitimate [marketing and recruitment] purposes” to provide the best services for our Clients.
If you are a Contact apart from one of our existing or impending Clients, we may collect data regarding:
- Your name
- Postal address
- Phone and email
- Details of role(s) within your organisation.
This information is held in our database and is attained by:
- Third party sites
- Information provided by you/when reaching out to us.
We collect, store and use your contact details for our legitimate interests, so that we can:
Contact you with marketing information that could benefit you and your organisation
Send you the details of Candidates and Consultants as well as contact you about our Services; and
Create and maintain our business relationship with you.
This allows you to be contacted to receive and administer any services which you or your organisation has requested.
For marketing activity we will not seek consent when sending materials such as newsletters, updates, Candidate CVs or Profiles, or salary surveys/white papers to a corporate postal or email address. These are necessary for legitimate interests for the good of fdu and our Clients. If you would like to withdraw consent or update your marketing preferences please contact us.
What is a cookie?
A cookie is a small text file that is downloaded when a user accesses a website. It allows the website to recognise that individual’s device and store some information about the individual’s preferences or past actions.
Rules on cookies
In order to comply with GDPR, fdu must:
- tell you the cookies are there;
- explain what the cookies are doing and why; and
- get your consent to store a cookie on your device.
Cookies are used in order to make our website work more efficiently and to provide us with information when you apply for a job. The table below provides information on all of the cookies used by our website.
Category 1: strictly necessary cookies
Category 2: performance cookies
Category 3: functionality cookies
fdu does not use advertising cookies.
The first time you visit our website you will be asked whether you consent to us storing cookies, as detailed in the table. Please tick the box, to confirm that you consent to us using cookies. If you do not consent, you will still be able to access our website, however, your ability to carry out certain functions, for example apply for a job, may be limited.
To find out more about cookies, including how to see what cookies have been set and how to manage and/or delete them, visit www.aboutcookies.org or www.allaboutcookies.org
8. Your Rights
What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
The right of access
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
The right to rectification
You are entitled to have your information corrected if it is inaccurate or incomplete.
The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to continue using it. This is not a general right to erasure; there are exceptions.
The right to restrict processing
You have rights 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 keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
The right to data portability
You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs 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 (i.e. if you no longer wish to be contacted with potential opportunities).
The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal 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 consent to us using your personal data for marketing purposes.
9. Request to have personal data amended
It is likely that over time your employment history will require updating as you transition to new roles or receive promotion. We undertake to update your registration within two weeks of receiving an updated Curriculum Vitae.
Under the GDPR you have the right to ask for access to your personal information. Once fdu has verified your identity we will provide the information you requested within 30 days.
In the unlikely event you find personal data stored about you by fdu is inaccurate, you must advise us immediately. We will amend your personal registration within two weeks.
10. Request to have personal data removed or deleted
Upon receipt of a request to delete an individual’s personal registration, fdu will ensure that your personal record is deleted within 30 days.
Where fdu has placed a Candidate in a role, fdu is required to retain evidence of that placing so that contractual obligations can be met by the Client. fdu will however take steps to ensure only minimal personal data is retained.
Where fdu has previously received permission to share personal information with a third party, for example for shortlisting for a role, we undertake to advise that third party of your wish to be forgotten if communication has been in the last 12 months.
In the event that you wish to be erased from our database you should contact firstname.lastname@example.org. Please make it clear that you wish to be erased, rather than simply marked as no longer job seeking.
11. Notification of Breaches
fdu stores financial information from Candidates relating to your salary and highly personal information contained within your Curriculum Vitae. We are aware of our responsibility as a recruiter to protect your information and to only share details with third parties upon receipt of your explicit consent. All of our systems are protected and only fdu staff and consultants working for fdu have access to the personal information stored in your registration.
In the unlikely event that our computer systems are compromised and there is a potential loss of confidentiality, we will report this breach to you.
In the unlikely event that personal data is taken or exposed from fdu records without our consent, we will provide reports surrounding that exposure within 72 hours of being notified of such an event and take any action necessary to restore security of your personal data.
If fdu receive a request for access to personal information we will verify your identify before releasing your personal data to you. We will not release information to any third party.
If you would like to make a request for access to your personal information please contact: email@example.com
Alternatively, you can contact us by writing to:
GDPR Compliance Officer
FDU Group Limited
16 Mortimer Street
13. Complaints procedure
If you have a complaint about the way your data is stored or handled by fdu, please contact us at: firstname.lastname@example.org
Alternatively you can contact us by writing to:
GDPR Compliance Officer
FDU Group Limited
16 Mortimer Street
14. Escalated Complaints
If you remain unhappy with the handling of your data you can complain to the ICO.
Information Commissioner’s Office
Studio 133 Canalot Studios, Kensal Road, London, W10 5BE
Company Number 5729463. Registered in the UK.
Candidate – defined as an individual who has previously indicated that they are interested in engaging with fdu with the purpose of us introducing potential new career opportunities to them. We will have been sent a copy of their Curriculum Vitae which will either have been submitted by them in relation to a specific role or submitted to inform us that they are keen on hearing about potential roles.
Client – defined as an organisation who may have a suitable career opportunity for one of our Candidates. This Client may be an active Client who is either currently working with us, a historic Client who has worked with us in the past or a prospect client who may work with us in the future.
Data – information which is being processed by equipment operating automatically in response to instructions given for that purpose, is recorded with the intention that it should be processed by means of such equipment, is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system or forms part of an accessible record.
EU GDPR – this is the European Union Directive which sets out principles relating to the use of data to ensure that the rights of the person who is the subject of the data are protected under the law.
Data subject – the person who determines the purposes for which, and the manner for which, any personal data is processed. Personal data – data which relates to a living individual who can be identified from that data, or from that data and other information which is in the possession of, or is likely to come into the possession of, fdu.
FDU Group Ltd. – t/a fdu and its subsidiary brands.
Sensitive personal data – personal data consisting of information as to the racial or ethnic origin of the data subject, political opinions, religious beliefs or other beliefs of a similar nature, me
embership of a trade union, physical or mental health or condition, sexual life, the commission or alleged commission of any offence or any proceedings related to any offence.
Third Parties – these are companies and people other than fdu and the group of companies of which it is part.
Users – people who use our website and register their details with us for the purposes of recruitment, either to gain employment or for the purposes of recruiting new staff.
Job – a paid position of regular employment.
Role – the function assumed or part played by a person or thing in a particular situation, in this case a job.