SpenglerFox Group Limited is a private company limited by shares incorporated in Ireland with company number 606426 and having a registered office at 2nd Floor, 1 Grant’s Row, Mount Street Lower, Dublin 2, Ireland (“we”/ “us”). We are an international organisation in the management consultancy sector (the “SFG”) which provides services which include but are not limited to executive search, interim management, human capital solutions, research, time to perform, board solutions and recruitment processing outsourcing (the “Services”). Outside of the SFG, the SFG has two franchises located in France and Greece (the “Franchises”). The SFG also has a number of global alliances (the “Global Alliances”) and partnerships (the “Partnerships”) which operate independently from the SFG.
This Policy sets out important information about your rights in relation to the processing of your personal data, and the basis upon which any personal data we collect from you, or that you provide to us, will be processed in connection with your use of this website, www.spenglerfox.com (“our Site” or “the Site”) and/or the Services. We do not knowingly attempt to solicit or receive information from children.
Controller and Processor.
Under this Policy, and unless we have entered into a different arrangement with you, we are both what’s known under the GDPR as the “controller” of the personal data you provide to us and the “processor” of personal data. We are a “controller” as we control personal data provided to us by our employees, clients and candidates and we decide on the purpose and means of processing this personal data.
Where we process personal data on behalf of our Global Alliances and Partnerships in relation to any particular referrals and/or assignments, we do so as a processor.
THE INFORMATION WE COLLECT
We will collect and process the following data about you for the following purposes:
Information you give us.
Your Data. This is information about you that you give us by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you use our Site, or the Services, or report a problem with our Site.
The information you give us may include:
- Identity Data: your full name, address, e-mail address, phone number, age, title, PPS number/Social Security Number/equivalent tax number, personal description, date of birth, gender, relationship status, photograph (including a copy of your passport or other identification documents) and professional membership details.
- Financial Data: your financial, including bank account details, billing contact email address, VAT number, salary information, pension contributions, PPS number/equivalent tax number and professional membership information.
- Candidate Data: employment history, employment details, curriculum vitae, cover letter, application forms, interview notes and references.
- Testimonial/Satisfaction Data: candidate survey and client survey.
Information we collect about you.
Automatically Collected Information. With regard to each of your visits to our Site we will automatically collect the following information:
- Technical Data: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, how often you use the application and other performance data; and
- Usage Data: information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
While the SFG can never guarantee that the transmission or processing of personal data is entirely risk free, especially the transmission of personal data over the Internet, the SFG is committed to ensuring personal data is processed in a lawful, fair, transparent and responsible way.
No special categories of personal data.
We do not require or collect any personal data that is your sensitive personal data or any special category of personal data under the GDPR, unless you decide to provide this information to us.
What are cookies and why we use them.
Cookies may be used to save your personal preferences so you do not have to re-enter them each time you access the Site.
WHAT WE DO WITH YOUR INFORMATION
We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
We have set out below, in table format, a description of the ways we plan to use your personal data and the legal basis we rely only to do so. We have also identified our legitimate interests where appropriate:
Type of data
Legal basis for processing
To respond to your queries and to provide you with the information you request from us in relation to our Services.
To provide the Services.
To provide online account set up, administration and access at our Site in relation to the Services.
To provide you with information about services we offer that are similar to those that you have enquired about.
Necessary for our legitimate interests (to develop our products or Services and grow our business)
Where you have given us your consent to do so, to provide you with information about other services we feel may interest you.
To ensure that content is presented in the most effective manner for you and for your computer or device.
Necessary for our legitimate interests (to keep our Site and the Services updated and relevant and to develop and grow our business).
To use data analytics to improve or optimise our Site, marketing, client relationships and experiences.
Necessary for our legitimate interests (to define types of clients for our products and services, to keep our Site and the Services updated and relevant, to develop and grow our business and inform our marketing strategy).
To measure or understand the effectiveness of advertising we serve to you and others, and, where applicable, to deliver relevant advertising to you.
Necessary for our legitimate interests (to study how clients use our products or Services, to develop them, to grow our business and to inform our marketing strategy).
To publish, upload, promote and disseminate information related to the SFG’s events, services and products to which may be of interest to you.
In the pursuit of the legitimate interests of the SFG to promote and provide information about the SFG, its business, events, services or products e.g. such as on the SFG’s website.
To allow and monitor access to the SFG’s premises.
To comply with a legal obligation to ensure the health, safety and wellbeing of the SFG’s employees in the workplace and to comply with its obligations under the GDPR.
To review your suitability for recruitment and to recruit
For the performance of a contract in relation to your employment by the SFG or in contemplation of entering into that contract.
To administer, protect and improve our systems, websites and business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
Necessary to comply with a legal obligation.
To provide you with information about job opportunities
Performance of a contract in relation to candidates not on an assignment
Legitimate interest in relation to candidates on assignment
To provide client/candidate testimonials
Legitimate Interest to promote and develop the business of the SFG
To provide and conduct salary surveys and client satisfaction surveys
Legitimate interest to promote and develop the business and monitor the SFG performance.
To comply with a request to unsubscribe or request for deletion
Legitimate interest to ensure that you are not contacted again (minimum information retained and any further processing is restricted).
Necessary to comply with a legal obligation.
Where you have given us your consent to do so, to include your photograph (which you have furnished us with your C.V. or which is on your social media account) to your personal profile or file within our FileFinder system for the purposes of providing our services to you.
If personal data is required to be collected and processed by the SFG in order to comply with a statutory or contractual requirement, or if it is a necessary requirement to enter into a contract, the SFG will inform you of this and of the possible consequences should you fail to provide this personal data.
At the end of an assignment, the SFG may send you a questionnaire. You are not under any obligation to complete this questionnaire. The SFG will use this information to monitor the SFG performance and to develop and grow its business and, to the extent the completed questionnaire contains your personal data will not, without prior consent, use your personal data for any alternative purpose.
Change of purpose.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at dataprotection@SpenglerFox.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with this Policy, where this is required or permitted by law.
How long we keep your information.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This means that the period of time for which we store your personal data may depend on the type of data we hold. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. This may vary according to legal requirements or other regulatory requirements in a particular country. For more information about our data retention policies please contact us at dataprotection@SpenglerFox.com.
DISCLOSURE OF YOUR INFORMATION
We do not sell your personal information to third parties for marketing purposes. We may disclose information to third parties if you consent to us doing so as well as in the following circumstances:
You agree that we have the right to share your personal information with the following recipients or categories of recipients:
- any department or authorised person within the SFG, or any member company within the SFG, which means any subsidiary or holding company within the meaning of sections 7 and 8 of the Companies Act 2014, some of which are located outside of the European Economic Area (the “EEA”).
- Selected third parties including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you in relation to the Services, this may include our Franchisees, Global Alliances and Partnerships;
- government agencies, authorities or departments for the purposes of complying with any security requirements or legal obligation in relation to the Services;
- analytics and search engine providers that assist us in the improvement and optimisation of our Site.
We will disclose your personal information to third party recipients:
- in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of our business or assets;
- if all or substantially all of our business or assets are acquired by or transferred to a third party whether in the event of a merger, reorganisation, transfer of undertakings, receivership, liquidation or other winding up or any other similar circumstances, in which case personal data held by us will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any law, legal obligation or court order, or in order to enforce rights under the GDPR or other agreements;
- to protect our rights, property or safety and of our customers, or others. This includes exchanging information with other companies and organisations for the maintenance and security of the Site and Services.
Personal Data may be shared and/or transferred to our trusted partners and service providers who maintain their servers outside of the EEA, where the privacy and data protection laws may not be as protective as those in your jurisdiction. This may include our Franchisees, Global Alliances and Partnerships. This is only for the purposes of providing, and to the extent necessary to provide, the Services to you. There are special requirements set out under Chapter V of the GDPR (with which we would comply) to regulate such data transfers and ensure that adequate security measures are in place to safeguard and maintain the integrity of your personal data on transfer.
For more information about this and the safeguards in place relating to the transfer, please contact us by email at dataprotection@SpenglerFox.com.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
YOUR PERSONAL DATA AND YOUR RIGHTS
Accessing your Personal Data.
You may request access at any time to a copy of the personal data we hold about you. Any such request should be submitted to us in writing and sent to dataprotection@SpenglerFox.com. We will need to verify your identity in such circumstances and may request more information or clarifications from you if needed to help us locate and provide you with the personal data requested.
There is usually no charge applied to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.
Right of Restriction.
You may restrict us from processing your personal data in any of the following circumstances:
- you have contested the accuracy of the personal data we hold on record in relation to you or for a period of time to enable us to verify the accuracy of the personal data;
- the processing of your personal data is unlawful and you request the restriction of use of the personal data instead of its erasure;
- we no longer require your personal data for the purpose of processing but you require this data for the establishment, exercise or defence of legal claims; or
- where you have contested the processing (under Article 21(1) of the GDPR) pending the verification of our legitimate grounds.
Corrections or Erasure (Right to Rectification and Right to Be Forgotten).
If we hold personal data concerning you which are no longer necessary for the purposes for which they were collected or if you withdraw consent for us to process your personal data, you can request the deletion of this personal data. We will retain minimal personal data in order to comply with this request. This right, however, will not apply where we are required to process personal data in order to comply with a legal obligation or where the processing of this information is carried out for reasons of public interest in the area of public health. If the personal information we hold about you is inaccurate, you may request to have your personal information updated and corrected. To do so at any time, please contact us by email at dataprotection@SpenglerFox.com.
Your Right to Object.
You have the right to object to the processing of your personal data at any time:
- for direct marketing purposes;
- for profiling to the extent it relates to direct marketing;
- where we process your personal data for the purposes of legitimate interests pursued by us, except where we can demonstrate compelling legitimate grounds for this processing which would override your interests, rights and freedoms or in connection with the enforcement or defence of a legal claim.
To exercise your right to object at any time, please email dataprotection@SpenglerFox.com.
Should you object, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above. We will retain minimal personal data in order to comply with this request. For more information about our marketing practices, please see the Marketing Communications section below.
Where we process your personal data by automated means (i.e., not on paper) and this processing is based on your consent or required for the performance of a contract between us, you have the right to request from us a copy of your personal data in a structured, commonly used machine-readable format and, where technically feasible, to request that we transmit your personal data in this format to another controller.
Profiling is an automated form of processing of personal data often used to analyse or predict personal aspects about an individual person. This could relate to a person’s performance at work, economic situation, health, personal preferences, reliability, behaviour, location or movements. An example of this would be where a bank uses an automated credit scoring system to assess and reject a loan application.
You have the right to be informed if your personal data will be subject to automated decision making, including profiling. You also have the right not to be subject to a decision based solely on automated process, including profiling, where that decision impacts on your legal rights. There are some exceptions to this rule, where, for example, the decision is necessary in connection with the performance of a contract between us, is authorised by law or where you have given your explicit consent to this automated processing. In this case, however, we do not engage in profiling or automated processing for profiling purposes.
The rights described in this section are personal rights and are exercisable only by the individual person (or data subject) concerned.
From time to time, we will use your data to send marketing communications to you about promotions, competitions, updates and new products or services that may be of interest to you. As mentioned above, and unless otherwise indicated, when we send marketing communications to you we rely on our legitimate interests to keep our site and Services updated and relevant and to develop and grow our business. If you subscribe to receive job alerts or updates from us or any other social media platform of which we have an account, we may send them to you from time to time about job opportunities that may be of interest to you. You can opt out of receiving such communications from us at any time by contacting us at dataprotection@SpenglerFox.com.
Your right to object to marketing.
You have the right to object at any time to the processing of your personal data for our marketing purposes. To do so at any time, please contact us at dataprotection@SpenglerFox.com. You may also opt out of receiving marketing communications at any time by selecting the unsubscribe option when you receive an electronic marketing communication from us.
THIRD PARTY MATERIAL
CHANGES TO THIS POLICY
Any changes made to this Policy from time to time will be published at the Site.
Any material or other change to the data processing operations described in this Policy which is relevant to or impacts on you or your personal data, will be notified to you in advance by email. In this way, you will have an opportunity to consider the nature and impact of the change and exercise your rights under the GDPR in relation to that change (e.g., to withdraw consent or to object to the processing) as you see fit.
QUESTIONS OR COMPLAINTS.
Contact Us. If you have any questions or complaints relating to this Policy, please contact us at:
SpenglerFox Group Limited
1 Grant’s Row,
Mount Street Lower,
Supervisory Authority. We are committed to complying with the terms of the GDPR and to the processing of personal data in a fair, lawful and transparent manner. If, however, you believe that we have not complied with our obligations under the GDPR, you have the right to lodge a complaint with the Data Protection Commission, Canal House, Station Road, Portarlington, County Laois, R32 AP23, Ireland.
Effective Date of this Policy: May 2018