ZRG Partners Commitment to the General Data Protection Regulation (GDPR)
Update: May 2018
Under General Data Protection Regulations from 25th May 2018, this privacy notice explains how ZRG Partners, LLC use any personal information we collect about you.
Section 1 – What personal information do we collect about you?
We collect the information necessary to be able to match available opportunities and further information needed to assess your eligibility through the different stages of recruitment. This information includes your name, contact details, family details, CV’s, educational records, work history, employment status and references.
We sometimes also collect sensitive personal information about you, such as details of criminal convictions and ethnic origin. We only collect sensitive personal information from you, and further process this data, where you have given your explicit consent or otherwise where permitted by law.
Section 2 – Where do we collect personal information about you from?
The following are the different sources we may collect personal information about you from:
- Directly from you. This is information you provide while searching for a new opportunity (for example when you provide a CV) and/or when we approach you with regard to a potential opportunity. This could be during telephone conversations, video conferencing, face-to-face interviews or email exchange. We may collect personal information with regard to employment preferences, strengths and work experience which 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 engage in discussion or submit your CV, you are providing permission for our storage of this information. ZRG Partners, LLC will never share personal information or a Curriculum Vitae with a third party without your explicit consent.
- From an agent/third party acting on your behalf.
- Through publicly available sources. We use a range of public sources including:
- Facebook & Twitter
- Company Web sites and other social media platforms
- Professional Organization websites
- Conference brochures/delegate lists
- 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.
- Current employer details
Section 3 – How do we use your personal information?
We use your personal data to match your skills, experience, education and interests against a specific brief or requirement with a potential employer. We will initially collect basic information on you such as job title, role, experience and contact details to assess a potential match to the requirement. Basic information, excluding contact details, may be shared with the client at this stage.
Once we have determined your interest in an opportunity, or to be considered for future opportunities, we will collect further information from you to share with the client or retain for future clients. This will only be done with your approval. If you are selected to progress through further stages of a recruitment process, we will collect additional information such as due diligence requirements and information from referees, whom you have nominated.
To provide a requested service or carry out a contract with you.
Where we have your consent
If you contact one of our Executive Researchers directly and request they consult with you regarding your job search, or regarding a particular job role, you are giving your consent to ZRG Partners, LLC processing your email and the data contained within your email for lawful purposes, as per section 2 above.
By sending an updated Curriculum Vitae directly to one of our Executive Researchers you are giving consent to ZRG Partners, LLC processing and storing that information, as per section 2 above. We will not share your information with any third party without your explicit consent.
Where we have a legitimate interest
We use certain personal data to determine which candidates might be worth approaching for a particular role. This is necessary for our legitimate interests as a search company. We don’t use any sensitive personal data without ensuring we have another basis for such processing.
Section 4 – How long do we keep your personal information for?
We keep your information for the following periods:
Candidate and client data: Due to the nature of executive recruitment, a significant number of candidates reconnect with our organization 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 for a period of ten years from the date of the last contact, or until such time as you wish us to delete your records from our database or refrain from further engagement.
Section 5 – Who do we share your personal information with?
We share your personal information with the search companies providing a service to their clients (the hiring company) and also directly with the hiring companies, in order to determine with the client(s) whether you are a good fit for the available position.
We share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems, research and mailing houses and function coordinators. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.
As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your personal information will be disclosed to such entity. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties.
Where required we share your personal information with third parties to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce any applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the our website, our business or the public.
Section 6 – Information Security
ZRG Partners, LLC use the Bullhorn candidate database. Any data hosted by Bullhorn CRM is fully encrypted and benefits from intrusion detection systems and regular penetration tests.
Section 7 – 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 information necessary or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide recruitment services to you, we may not be able to match you with available job opportunities.
Section 8 – Do we make automated decisions concerning you?
We do not carry out automated decision making.
Section 9 – We transfer your personal information outside the EEA on rare occasions.
To better match your employee 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.
The countries that we send data to outside of the EEA have adequate protection of personal data as determined by the European Commission.
We occasionally send data to the US under the Privacy Shield Framework.
Section 10 – What are your rights?
By law, you have a number of rights when it comes to your personal information. Further information and advice about your rights can be obtained from the data protection regulator in your country.
|Rights||What does this mean?|
|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 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.|
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’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 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 information 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 lodge a complaint||You have the right to lodge a complaint about the way we handle or process your personal information with your national data protection regulator.|
|The right to withdraw consent||If you have given your consent to anything we do with your personal information, 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 information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal information 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
- 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.
Section 11 – 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.
Section 12 – How can you contact us?
If you have any enquires you can contact us at email@example.com or by writing to us at:
Data Protection Officer
ZRG Partners, LLC
365 West Passaic Street
Rochelle Park, NJ 07662