This policy explains how we process personal data within our global businesses delivering search, consulting and assessment services, including how it affects our website

Wilson Brook ("we", "us") is committed to keeping your information secure and managing it in accordance with our legal responsibilities, under the privacy and data protection laws applicable wherever we operate in the world, as well as the General Data Protection Regulation (Regulation (EC) 2016/679 (“GDPR”) in the European Union (“EU”).

We keep this Privacy Policy under regular review and update it from time to time.

This policy was last updated in January 2019. Please review this policy periodically for any changes.

Who this policy applies to

We provide executive search, assessment and leadership services (“our services”) to a range of clients throughout the world. Details of our services can be found elsewhere on this website or those listed above. This policy applies to you whether you are a candidate for one of our clients, an individual we are assessing as an employee of one of our clients, a client or whether you are a source or a referee in respect of a candidate or an employee of one of our clients.

For the purposes of this policy:

candidate(s) means an individual who is a candidate, applicant, potential candidate, employee of a client;

client(s) means any, business, firm, organisation, government body or individual that mandates us to perform any of our services;

referee is a person who provides a personal or work reference in respect of a candidate and;

source is a person who provides us with information or intelligence about a candidate.

Gathering information

Our clients expect that we identify the best individuals to fill roles within their organisations. So, we need to research systems, online databases and other information sources, and talk to many individuals. Besides our clients, these will include referees and sources to help inform our decision-making process.

The nature of our work means we are required to process personal data quickly, confidentially and often without reference to the data subject. Accordingly, we process such data in accordance with the Data Protection Laws, regularly using our legitimate interest where it is not possible or feasible to speak directly with the data subject. Beyond this, we will seek consent in the circumstances explained later in this policy document.

We collect information from candidates directly when you upload your CV or resume into our candidate portal or when you send this to us via email or post. We also collect information from you when you speak with a Wilson Brook employee.

How we use your personal data

Candidate

• We use the personal data we collect from you for a number of purposes:
• Processing job applications, in partnership with our clients, on whose behalf we are instructed to help fill a job vacancy. This means that if you apply for a specific job, we may pass your details to the relevant client to proceed with the application. As a result you may receive further direct correspondence from them.
• Searching for relevant candidates for confidential recruitment assignments where our client is not initially named. This means that if we believe you are suitable for a specific role, we may pass your basic details on to the relevant client. If that client agrees that you might be suitable, we will then discuss this with you in more detail. You might be interviewed for the role by one of our consultants. If successful, you might be shortlisted for interview by our client. At this point, we will pass further details to the client and you may receive further direct correspondence from them.
• From time to time, we conduct mapping or research exercises on behalf of our clients. This is to enable them to understand a particular market. Here, we may include certain aspects of your personal data. You will not be contacted by any third party about this unless we first obtain your consent.
• For the performance of a contract, we have concluded with you as an individual, most likely an assessment or coaching programme.
• For equality monitoring purposes, to understand the diversity of our applicant pool, but only if admissible under the applicable law. (This information is anonymised and aggregated).
• Improving the service we offer. For example, you may be asked to complete one of our online satisfaction surveys.
• For marketing purposes to send you information on our services, white papers, newsletters, events and so forth. Please note you may opt out from receipt of marketing materials at any time by writing to us.

We will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others or, have your permission to do so.

Please be aware that we are not responsible for the data processing activities of others, such as our clients.

Client

We will use client data to perform our services to you and other legitimate business purposes such as marketing.

Source and Referee

We will use source and referee data to perform our services, in particular to enable us to obtain your opinions on a candidate.

We may also use this information to enable us to market our services to you as a potential client. We may as well invite you to become a candidate in respect of the provision of our services.

The type of personal data we collect and process

In all cases we collect and process personal data about you, including your name, address, telephone number and email address.

Candidate

If you proceed with a job application, or should we consult you about a role, you may be required to submit additional personal data. For example, date of birth, education and career history and curriculum vitae (CV), or resume. Your CV or resume may contain employment history, education, professional qualifications, memberships, details of papers written, references and referees, amongst other things.

Based on your explicit consent, we will also process any relevant psychometric assessments, psychological tests, or results from such assessments or tests.

From time to time, we may ask you to provide information relating to protected characteristics, such as your race or marital status. We do this for equal opportunity monitoring purposes and from time to time online, but only if that’s admissible under local law. This information is always anonymised and aggregated and will not be revealed to third parties without your specific consent.

We might also collect personal data from third-party databases and other public sources.

Client

As well as basic contact information we will also collect information about your role and other information provided to us by your organisation.

Source and Referee

As well as basic contact information we will also collect information regarding your credentials as a source, details of your relationship / knowledge of a candidate and your opinions of that individual. We may obtain this information directly from you or publicly available information.

What we do

For certain roles, we may run an advertisement to which you may respond, either electronically or via mail. Other roles may involve one of our researchers or consultants calling you to discuss the details. Then, we will either inform you verbally that we will process your personal data or send you a Data Privacy Notice. Both will direct you to this Privacy Policy.

Besides filling particular leadership vacancies, we also process personal data when we conduct market intelligence exercises to map out particular business sectors or functions to help clients understand the available talent.

Sensitive data

From time to time, we will seek your consent to process personal data in respect of certain specific and limited purposes. We will always do this before processing any sensitive personal data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sex life and sexual orientation, genetic and / or biometric data. We encourage you not to provide us with sensitive personal data, unless it is specifically requested, and we have your consent.

Local agreements

In certain countries, we will not collect personal data from you unless you have specifically agreed to this. Your agreement might come via an electronic tick-box on our website or other electronic channels, or via other similar measures required by local privacy and data protection laws.

We may also provide services to our clients in certain countries that entail the assessment and coaching of their employees. Here, depending on the specific assignment, we will either process your personal data to meet the legitimate interests pursued by the client, or act on their behalf, in accordance with their instructions. If our services include any psychometric assessments or psychological tests, and we’re not acting on behalf of your employer, we will obtain your specific consent.

In some locations, we provide services to individuals, such as assessment and coaching. Here, we will process personal data for the performance of the contract with you. If our services include any psychometric assessments or psychological tests, we will obtain your specific consent.

Your right to object and to have your data erased

You are not obliged to provide any personal data to us. However, please note that this may mean we will not be able to consider you in respect of any of our services. 

Remember, you may withdraw any consent you have previously given, at any time. Also, you have the right to ask us to stop processing any personal data and to have it erased. 

In these circumstances, we reserve the right to maintain basic personal data such as your name and address. This is to ensure your personal data isn’t processed by us in the future.

Please note that no automated decisions, such as computerised candidate profiling, are made on the basis of the information we collect.

Newsletters and other communications

If you would like to receive one of our newsletters, we will ask you to provide us with your name, email address, job title, company name and country of residence. 

When you have indicated you would like to receive newsletter(s) from us, we may send email alerts and bulletins about our services and any roles that might interest you.

You can unsubscribe from our electronic marketing messages by following the “unsubscribe” instructions included in our communications. Also, you may change your preferences and cease receiving direct marketing from us through your email account settings.

From time to time, we may contact you with updates on our services, terms of business or simply to ensure that the data we hold is current, relevant and up to date.

Satisfaction surveys

If you take part in a user satisfaction survey, we may ask you to provide us with personal data, including your name, email address, and your views and opinions.

Providing information to others

To help us run this website, and to provide executive search services or assessment services in certain countries, we work closely with trusted partners with whom we need to share personal data. These partners include:

• Our clients, for whom we provide executive search services.
• Our clients, for whom we provide assessment and coaching of their employees in certain countries.
• Prospective clients, where we might need to demonstrate an understanding of a particular market and the individuals that work within it.

We will share information only as anticipated within this Privacy Policy and, wherever appropriate, limit disclosure to information in aggregated form, to avoid or limit identifying you personally.

Where we share information with such a third party, you will not be contacted by them, unless we have obtained your prior consent.

Third parties

We may also provide information to third party service providers who process information on our behalf. This is to help run some of our internal business operations, including email distribution, IT services and customer services. As part of our agreements with them, these third parties are required to process such data securely and only in accordance with our instructions. 

Your information may also be shared with organisations located elsewhere in the world. As their privacy laws may not match your home country’s standards, we’ll only make a transfer data if adequate levels of protection are in place to protect any information held in that country, or the local service provider complies with applicable privacy laws at all times.

Where required by law, we will take measures to ensure that personal data handled in other countries will receive at least the same level of protection as in your home country. 

We may sometimes be required to disclose information about you to law enforcement bodies, agencies or third parties, under a legal requirement or court order. We will act responsibly and take account, where possible, of your interests when responding to these requests.

If you are concerned about these arrangements to disclose or share personal data with third parties, you should contact us and ask us not to process your personal data.

Keeping information secure

We invest significant resources to protect your personal data, from loss, misuse, unauthorised access, modification or disclosure. However, no system can be 100% secure, and so we cannot be held responsible for unauthorised or unintended access that is beyond our reasonable control.

Information about others

If you provide us with information about other individuals, like details of a referee or personal contact, you must ensure they’ve agreed to this. We would advise you to keep a record of their agreement and provide them with a copy of, or link to, this Privacy Policy.

Keeping your records

We keep your personal data for as long as required to provide our services, and in accordance with legal, tax and accounting requirements. Where your personal data is no longer required, we will ensure it is disposed of in a secure manner. Where required by law, we will notify you when this has happened.

Access rights

In some jurisdictions, you may have the right to request copies of your personal data held by us. If you think any of that data is inaccurate, you may also ask us to correct it. You may also have a right, in certain circumstances, to require us to stop processing your personal data. Also, you have the right to ask us to transfer your personal data to someone you nominate for your own purposes.

To get in touch with us about any of this, please email or write to us at the address below. Please note that we may request proof of identity. We will respond to your requests within the time frame that applies in the country concerned.

In certain circumstances, in countries where it is required or permitted by law, we might not be able to provide you with access to some of your personal data. Wherever possible, we will notify you of the reasons for this.

About this website

This Privacy Policy applies to our websites too, where we process personal data within and through this website

The primary purpose of this websites is to provide you with information regarding the services provided by Wilson Brook. 

We use the personal data we collect from you on our website for additional purposes such as personalising the look and feel of the website to fit the personal preferences inferred from how you’ve used the site. (See the "Analytics" and "Cookies" sections for more information.)

We may disclose or share personal data with third parties as outlined above to operate the website and provide our executive search services, as well as assessment services in certain countries. If you are concerned about these arrangements, you should not use the website and contact us to ask us not to process your personal data.

Finally, we might also use your data, to help our clients understand who is making use of our website and how their job vacancies are being viewed.

Updating your account and preferences

If you register an account with us, or with a local partner who provides a job application portal on our behalf, please do keep your details up to date, and notify us of any changes to your personal data. You can do this by updating your user preferences through your account login, or by contacting us using the details below.

Analytics

We use analytics tools and cookies on this website to help deliver our online services, identify any service issues, improve our services, provide content tailored to users' personal preferences, and to monitor site traffic and usage.

These tools may be provided by third-party service providers and may include the collection and tracking of certain data and information regarding the characteristics and activities of visitors to our website. We may disclose data, including personal data, to certain third-party services providers in order to obtain such services.

One of these providers is Google Analytics. More information about the ways in which they collect and process your personal data can be found here: www.google.com/policies/privacy/partners

You can opt-out of Google Analytics here: tools.google.com/dlpage/gaoptout

Cookies

Cookies are small computer files which are downloaded onto your device when you browse the web. They collect information about the way in which you navigate and use this website and the wider web. This information may allow us to identify you or your approximate location. Cookies also help us provide you with a more personal experience, like a local version of the website in a local language. Information from cookies also allows us to make improvements to our services.

We only collect "session" cookies, which are not usually stored after your browsing session has ended. These are used to establish your approximate location and to serve up the website in an appropriate language. (IP address collection happens during this process.)

You may delete and block all cookies, or just certain types of cookies, via your browser settings. However, if you choose to block or delete cookies, this may affect the functionality of the website.

Third party websites

This Policy only applies to this website. If you land on our site from other websites, or move to other ones from our website, you should read their separate privacy policies.

Complaints procedure

If you have a complaint about how we have handled your personal data, contact us using the details below, and we will investigate your complaint. Please use the same contact details to instruct us to cease processing your personal data.

Contacting us

If you have any questions about this Privacy Policy, or would like to exercise your rights with respect to your personal data, please contact us at info@wilsonbrook.com

Cookies

Cookies are quite simply small pieces of text held in files that are stored on your computer. They are usually placed there by websites and enable the webmaster to have access to useful information in regards to your site preferences, location, language etc. It is actually very useful for you, the user, as it means that sites can run more effectively for you, enabling you to surf from page to page without having to re-enter information or preferences.

Generally, we have 3 types of cookies used throughout our web pages

• Cookies are deleted every time you close your browser, called sessions.
• Cookies that are stored until deleted or after a set period to save your preferences etc.
• Cookies set by external companies that have been pre-approved by us to help your experience.

A number of our cookies are considered essential for the site and others optional.

We cannot access personal information or gain access to your computer using cookies. They simply share with us information of your choosing via inputs or forms on our site.

Before deleting or rejecting cookies on your browser, please be advised that doing so means that some sections of the website and other websites you visit may not function.

However, if you still wish to remove the cookies from your browser or to block them from ever being set in the future you can do so from the browser you are viewing this page in now. You have the choice to block all cookies or only particular ones depending on your choice. In addition to this you can also configure your browser to notify you each time a request to set a cookie is made.

If you would like to know how to monitor your cookies then visit www.aboutcookies.org for some useful information on controlling cookies in all browsers.

In the same manner, if you would like to remove all the cookies from any browser then visit www.aboutcookies.org for up to date instructions on removing cookies from any browser, old or new.

In addition to this, the help section of your browser should be able to help you find the answers you are looking for. Other useful resources on monitoring cookies can be found below:

• http://privacy.microsoft.com/
• http://www.mozilla.org/en-US/privacy/

Google Analytics cookies are used on almost every site on the web these days because they provide very useful information on how visitors use individual web sites. We use Google Analytics to help us improve the site and they provide us with anonymous information on how visitors arrive at our site, where they have reached us from and which pages they viewed, when and for how long. If you would like more detailed information on Google Analytics cookies, you can find it here: Cookies & Google Analytics.

Cookie NameExpiresUsage_utma2 yearsDetermines unique site visitors_utmb30 minsEstablish/Continue a session_utmcNot setRandomly generated number_utmz6 monthsDetermines site referral

There is a lot of information on the web about cookies, but you can find all the information you need here at www.allaboutcookies.org, which provides all the information you need on what exactly cookies are and how to manage, restrict, block or delete them. If you are viewing this on a mobile browser you will need to read your mobile browser handbook.

This is the Wilson Brook website, www.wilsonbrook.com Your use of this website is subject to the following terms and conditions, which you are deemed to accept each time you use the website:

Whilst we try to ensure that the standard of this website remains high and to maintain the continuity of it, the internet is not an inherently stable medium, and errors, omissions, interruptions of service and delays may occur at any time. We do not accept any liability arising from any such errors, omissions, interruptions or delays or any ongoing obligation or responsibility to operate this website (or any particular part of it) or to provide the service offered on this website. We may vary the specification of this site from time to time without notice.

On this site you will be offered automatic links to other sites which we hope will be of interest to you. We do not accept any responsibility for or liability in respect of the content of those sites, the owners of which do not necessarily have any connection, commercial or otherwise, with us. Using automatic links to gain access to such sites is entirely at your own risk. Likewise, our linking to a third party website should not be interpreted as a form of endorsement or recommendation for the products or services offered on the third party's site in question.

Whilst we make every effort to ensure that the information on this site is accurate and complete, some of the information is supplied to us by third parties and we are not able to check the accuracy or completeness of that information. We do not accept any liability arising from any inaccuracy or omission in any of the information on this site or any liability in respect of information on this site supplied by you, any other site user or any other person.

Unless otherwise stated, the copyright and similar rights in this website and in all the material contained on this web site belong to Wilson Brook. You are only permitted to copy or print extracts of the material for your own personal use. You may not use any of this material for commercial or public purposes.

Without written permission, you may not (whether directly or indirectly including through the use of any programme) create a database in an electronic or other form by downloading and storing all or any part of the pages from this website. Without the permission of Wilson Brook, no part of this website may be reproduced, transmitted to or stored on any other website, disseminated in any electronic or non-electronic form, or included in any public or private electronic retrieval system. Any request for such permission may be sent to Wilson Brook by e-mail to info@wilsonbrook.com

You may only use this site for lawful purposes when seeking employment or help with your career or when recruiting staff. You must not under any circumstances seek to undermine the security of the site or any information submitted to or available through it. In particular, but without limitation, you must not seek to access, alter or delete any information to which you do not have authorised access, seek to overload the system via spamming or flooding, take any action or use any device, routine or software to crash, delay, damage or otherwise interfere with the operation of this site or attempt to decipher, disassemble or modify any of the software, coding or information comprised in the site.

You are solely responsible for any information submitted by you to this site. You are responsible for ensuring that all information supplied by you is true, accurate, up-to-date and not misleading or likely to mislead or deceive and that it is not discriminatory, obscene, offensive, defamatory or otherwise illegal, unlawful or in breach of any applicable legislation, regulations, guidelines or codes of practice or the copyright, trade mark or other intellectual property rights of any person in any jurisdiction. You are also responsible for ensuring that all information, data and files are free of viruses or other routines or engines that may damage or interfere with any system or data prior to being submitted to this site. We reserve the right to remove any information supplied by you from the website at our sole discretion, at any time and for any reason without being required to give any explanation.

We will use information supplied by you (including, without limitation, sensitive personal data) to aid the recruitment process and associated administrative functions. This involves us, amongst other things, processing and storing information and passing or making available such information to prospective employers and clients; information about opportunities and placements will be passed to candidates and may be posted directly onto the website. We may collect and aggregate data from the information supplied by you to help us to understand our users as a group so that we can provide you with a better service. You consent to us using information provided by you in each of these ways. We will process any data which you provide in completing the online registration or application forms and any further forms, assessments or personal details which you complete or provide to us when using this site in accordance with UK data protection legislation. We explain more about your personal data in our Privacy Policy.

We accept no liability for any loss (whether direct or indirect, for loss of business, revenue or profits, wasted expenditure, corruption or destruction of data or for any other indirect or consequential loss whatsoever) arising from your use of the site and we hereby exclude any such liability, whether in contract, tort (including for negligence) or otherwise. We hereby exclude all representations, warranties and conditions relating to this website and your use of it to the maximum extent permitted by law.

You agree to indemnify us and keep us indemnified against all costs, expenses, claims, losses, liabilities or proceedings arising from use or misuse by you of this site.

You must notify us immediately if anyone makes or threatens to make any claim against you relating to your use of this site.

Wilson Brook reserves the right, at your cost, at any time to remove any material from the site which it believes to be salacious, defamatory or offensive or which Wilson Brook believes may be in breach of a third party's rights, such as a third party's intellectual property or confidentiality rights. You agree to indemnify Wilson Brook on a full and continuing basis against any loss or damage suffered or costs (including legal costs) incurred by Wilson Brook in defending any action brought against Wilson Brook as a result of any information you have posted on the website.

The use of this website and any agreements entered into through this website are to be governed by and construed in accordance with English law. The courts of England are to have exclusive jurisdiction to settle any dispute arising out of or in connection with the use of this website or any agreement made through this website.

Some of the goods or services offered through this website may not be lawful or may otherwise not be permitted in certain countries outside the United Kingdom. If you attempt to order, receive, purchase or otherwise benefit from any such goods or services, we do not accept any liability for any losses suffered by you in using this website which you would not have suffered had you been accessing this website as a United Kingdom resident (including as a result of us being prevented from dealing with any application or enquiry by any law, regulation or other ruling applicable in any country).

Confidentiality: The information in any e-mail and any attachment is confidential and intended for the named recipient(s). If you are not a named recipient please notify the sender immediately, do not disclose the contents to another person or take copies. Please delete the e-mail immediately.  Attachments to e-mails may contain software viruses which may damage your systems. Wilson Brook has taken all reasonable precautions to minimise this risk, but we advise that any attachments are virus checked before they are opened. Wilson Brook cannot accept responsibility for any virus transmitted by our staff. Wilson Brook does not accept liability for any defamatory statement made by its staff. Any views or opinions presented are solely those of the author and do not necessarily represent those of Wilson Brook 

These website terms and conditions may be changed by us at any time. You will be deemed to accept the terms and conditions (as amended) when you next use this site following any amendment.

If any provision of these terms and conditions is held to be invalid by a court of competent jurisdiction, such invalidity shall not affect the validity of the remaining provisions, which shall remain in full force and effect.

Wilson Brook Consulting Limited is a private limited company registered in England & Wales.  Registration number 11721104.  Registered office:   8 Church Green East, Redditch, Worcestershire B98 8BP