Who are we?
Sousou Partners provides executive search services and we take your personal data seriously. This policy:
- sets out the types of personal data that we collect about you
- explains how and why we collect and use your personal data
- explains when, why and with who we will share your personal data;
- sets out the legal basis we have for using your personal data;
- explains the effect of refusing to provide the personal data requested;
- explains the different rights and choices you have when it comes to your personal data; and
- explains how we may contact you and how you can contact us.
What personal data do we collect, about you?
We collect the information necessary to be able to find available opportunities and further information needed to assess your eligibility through the different stages of recruitment. This information includes CV’s, educational records, work history, employment, and references. We may also collect sensitive personal data about you, in the form of compensation and if required family composition information. We only collect sensitive personal data from you, and further process this data, where you have given your explicit consent.
Where do we collect personal data about you from?
The following are the different sources we may collect personal data about you from; Directly from you, through publicly available sources, by reference, or word of mouth.
How long do we keep your personal data for?
We only retain your information for 12 years after our last interaction 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:
a) our contractual obligations and rights in relation to the information involved;
b) legal obligation(s) under applicable law to retain data for a certain period of time;
c) our legitimate interest where we have carried out a balancing test;
d) (potential) disputes;
e) if you have made a request to have your information deleted; and
f) guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information once this is no longer needed.
How and why 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 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.
Who do we share your personal data with?
Your personal data is shared with the client who initiates a search for personnel. The search for which you are considered, to ascertain if you are a good fit for the available position. We may also conduct checks on you to verify the information you have provided.
What legal basis do we have for using your information?
For prospective candidates, 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 contact clients and referees. We carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests before we go ahead with such processing.
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.
For clients, we may also rely on our processing being necessary to perform a contract for you, for example in contacting you.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary or withdraw your consent for the processing of your personal data, we may not be able to match you with available job opportunities.
Do we transfer your data outside the EEA?
To better match your profile with current opportunities we may transfer your personal data to clients and partners in countries outside the EEA. These countries’ privacy laws may be different from those in your home country. Where we transfer data to a country that has not been deemed to provide adequate data protection standards we always have security measures and approved model clauses in place to protect your personal data.
At present, if the search requires, we transfer personal data to the following countries outside the EEA; Australia, Far East, Latin America, Middle East, or North America.
To find out more about how we safeguard your information as related to transfers and to obtain a copy of such safeguard, contact us using GDPR@sousoupartners.com.
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.
What are cookies and how do we use them?
Third-party cookies: We use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behavior patterns. This information is anonymous; we do not make and do not allow Google to make, any attempt to find out the identities of those visiting our website.
The data collected by Google for its subsequent analysis includes:
• Technical data regarding your device (model, operating system, specific device identifiers, and mobile network information, including Google apps}.
• Logging on data (search inquiries, phone numbers used to make, receive & forward calls, time, date, length & type of calls, etc.).
• Internet protocol address; Device activity (settings, browser types, languages, system operations, dates & times of URL request & referral.
• Cookies specifically linked to your browsers or accounts; Application installation data (installing & uninstalling certain services).
• Location (IP address, GPS, Wi-Fi access points and cellular towers);
• Localized device storage (browsing history, caches, etc.); Cross-website cookies or anonymous identifiers (Google features or ads appearing on other sites).
External Websites / Links: This Site contains links to other sites, note that these links are given as a service only unless specifically stated, Sousou Partners is not affiliated to any of the sites or companies nor is it responsible for the content of such sites or the services that such companies provide.
How to reject cookies: If you don’t want to receive cookies that are not strictly necessary to perform the basic features of our site, you may choose to opt-out by changing your browser settings. Most web browsers will accept cookies but if you would rather, we didn’t collect data in this way you can choose to accept all or some or reject cookies in your browser’s privacy settings.
However, rejecting all cookies means that you may not be able to take full advantage of all our website’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. For more information generally on cookies, including how to disable them, please visit the official website about cookies, aboutcookies.org. You will also find details on how to Delete cookies from your computer.
Rights – What does this mean?
- 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 on this Policy.
- The right to rectification: You are entitled to have your information corrected if it’s 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’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
- The right to object to 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 keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in the future.
- The right to data portability: You have the right 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 want 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.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
How will we contact you?
We may contact you by phone, email, or social media. If you prefer a particular contact means over another please just let us know.
How can you contact us?
If you are unhappy with how we’ve handled your information or have further questions about the processing of your personal data, contact us at GDPR@sousoupartners.com