This policy explains how Howgate Sable Humphreys Irving Ltd (Trading as Howgate Sable) (‘the Company’’) processes personal data.

Howgate Sable Humphreys Irving Ltd (Trading as Howgate Sable) (“the company”) is committed to ensuring that all the personal data we collect and process is managed in accordance with our legal responsibilities under privacy and data protection laws, including the General Data Protection Regulation (GDPR).

This policy is effective from 25th May 2018 and may be amended from time to time. This latest version was published on 11th October 2022.

What we do

We provide executive search services, both permanent and interim, to our clients. This involves identifying individuals who may be suitable to fill specific roles with those clients, obtaining further information about those individuals to enable us to assess their interest in and suitability for those roles, and ultimately providing details of suitable candidates to our clients.

From time to time we may also carry out exercises to map out business sectors or functions, to help clients benchmark or understand the wider talent market.

Who this policy applies to

This policy applies to all individuals with whom we may deal in the course of business, including:

• • candidates – actual or potential candidates, whether identified through our own efforts or due to their
  having provided unsolicited information to the Company. This may also include client employees who are
  under consideration for a role alongside the wider search.
  • clients – actual or potential clients, including any business, firm, organisation, government body or
  individual that mandates us to perform our services
  • referees/sources – individuals who may be able to provide us with information relevant to a mandate
  we are conducting, including the names of candidates.

• How we gather information and use personal data

• Candidates

• 
  We use a wide range of tools to initially identify candidates, including publicly available sources, online subscription services and talking with clients, referees or sources. Data collected will normally include name, job title, employer and limited contact information. This personal data is collected for legitimate business reasons to identify candidates that may be suitable for mandates we are handling for our clients. We may discuss the results of this identification process with our clients.
• 
  Following this initial identification, we may approach candidates by either email or telephone, with a view to obtaining further information that will enable us to assess their interest in and suitability for a mandate we are handling. Information collected may include contact details, CV, work history, education history, salary/package details, family information and the results of any psychometric testing. If we have not already done so, at this stage we will notify candidates that we are processing their personal data and direct them to this privacy policy. The basis for processing data is legitimate business interests. We may discuss this personal data with the client whose mandate we are handling, or pass the data on to them.
• 
  From time to time we may also need to collect limited information about protected characteristics such as race, health or religious beliefs, in which case we will seek specific consent to process this data. At no stage do we use any automated processing to make decisions.
• 
  Please note that we are not responsible for the data processing activities of others, in particular our clients.
• 
  
  

  Clients

• 
  We use client data to perform our services under the contract we have with that client and for other legitimate business purposes such as marketing. Clients may opt out of receiving marketing communications at any point. Client data will include names, job titles and contact details.

• Referees/sources

• 
  We use the personal data of referees/sources for the legitimate business purpose of fulfilling mandates from clients. The data we hold may include names, contact details, employer and job title.
  We may also use this information to enable us to market our services. Individuals may opt out of receiving marketing communications at any point.

• Data retention and security

• We retain personal data for as long as is required to provide our services, in accordance with legal, tax and accounting requirements. Where personal data is no longer required, we will ensure it is disposed of in a secure manner.
• We are committed to ensuring the appropriate security of the personal data we collect and store, in whatever form that data is held. This includes protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. However, no system can be 100% secure, and we cannot be held responsible for unauthorised or unintended access that is beyond our reasonable control.

• Data subject rights

Individuals have various rights under data protection law. In addition to the right to be informed that we are processing personal data, they may request copies of their personal data, ask us to correct any information that they think is inaccurate, withdraw their consent to processing at any stage or request that their data be removed.

About our website

This Privacy Policy applies to our website which can be found at www.howgate–sable.com. The primary purpose of our website is to provide information regarding the services provided by the Company.
As is true with most websites, our server will automatically log data regarding each visit such as IP address, browser type, referring/exit pages, and operating system. We may use this information to monitor server errors, server administration or to monitor visitor behaviour. Any user who does not agree to this happening should no longer use our website, as it is not possible for this to be disabled on a per–user basis.

Our website may include hyperlinks to other websites. Hyperlinks take users out of our website to other websites. Access to and use of these other websites will not be governed by this privacy policy and it is the user’s responsibility to check the other websites and the privacy policies that may govern those sites to ascertain how information and data will be treated.

Our website uses cookies which are stored on a user’s browser. Browser settings can be modified to prevent this happening. However, by disabling cookies, or certain types of cookie, the user experience on this and other websites may be modified or prevented from working entirely.

Contact details

If you have any questions about this Privacy Policy, would like to exercise your rights with respect to your personal data or have a complaint about how we have handled your data, please contact us at GDPR@howgate–sable.com or write to the address below.

Howgate Sable Humphreys Irving Ltd (Trading as Howgate Sable)
1 Old Hall Street
Liverpool
L3 9HF