The Howitt Partnership Ltd was set up in the belief that a strong and productive strategic recruitment relationship with its Clients and Candidates should based on a professional and ethical approach in relation to the protection of confidential data and information. This Policy sets out the basis on which any personal data we collect, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
This Policy aims to ensure compliance with the Regulation. The Regulation sets out the following principles with which any party handling personal data must comply. All personal data must be:
a) processed lawfully, fairly, and in a transparent manner in relation to the data subject;
b) collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;
e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject;
f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
For the purposes of data protection legislation the data controller is The Howitt Partnership Ltd, 11 Brightmoor Street, Nottingham, NG1 1FD.
The Data Protection Officer is:
Managing Director - Matthew Draper
Legitimate Business Purposes and Types of Personal Information collected:
The Howitt Partnership Ltd is a strategic search and career consulting business and we therefore collect Personal Information in connection with the services we provide.
As a candidate, if you submit an inquiry or question via an online form or email to our website, we collect your name, email address, or other Personal Information contained in your correspondence, including information shared in a typical profile or CV.
If you participate in our strategic search or consulting services, we collect your name, title, professional and personal contact information, demographic data, results of any assessment, survey, or questionnaire you complete, compensation, employment objectives, memberships, community involvement, details in your curriculum vitae (including your educational background, work history, and other qualifications), language skills, job performance, reputation, responses to interview questions, and financial details which we collect from you or third party sources such as online searches and professional contacts.
If you are a client or potential client, we collect your name, contact details, title or position, products or services requested, or other information that you provide including via online forms or email correspondence. Unless required or authorised by law, we do not process sensitive Personal Information about you, unless you have affirmatively consented to this processing.
Information collected upon visiting our website and "Cookies":
This website automatically collects certain device information such as your IP address, unique device identifier, Cookies (as discussed below), geographic data, country, browser, device operating system, application version, language settings, and pages that have been shown to you. Note, however, we do not consider this device information to be Personal Information except where we link it to you as an individual or where applicable law requires.
For further information on Cookie control and usage, please visit:
How we process the Personal Information:
We use the information we collect to support and develop our strategic search and career consulting services. The following paragraphs describe some of the ways in which we may use Personal and other information:
Strategic Search Services: We may use your Personal Information in order provide and improve on such services, such as sourcing, identifying, assessing, attracting and retaining talent for search projects on behalf of our Clients, sending you positions that may be of interest to you, providing advisory guidance on needs and trends for our Clients and sharing thought leadership that may be of interest to you.
Fulfilling your requests: We may use personal information to respond to your inquiries and fulfil your requests. If you contact us, we may keep a record of your contact information and correspondence, and we may use any information you provide in your message to respond to your inquiry.
Business purposes: We may use personal information for our own business purposes, such as audits, internal communication regarding candidates and clients, determining the effectiveness of our promotional activities, administering our products and services, maintaining and securing our infrastructure, and for procurement and financial transactions.
Additional activities for Search Services: In the course of our strategic search services, we use personal information that we have collected concerning Candidates to identify professional opportunities that we think may be of interest. We may contact potential Candidates from time to time regarding such opportunities. We also may contact individuals from time to time to solicit names of, or other personal information regarding, potential Candidates in connection with a strategic search that we are conducting and for purposes of market intelligence. We also use personal information to confirm references and conduct education and background checks, as appropriate. We may further use personal information that we collect for purposes of aggregating and disclosing diversity statistics and other statistical information regarding our candidates and placement activities.
Additional activities for Consulting Services: In the course of our Consulting Services, we may use personal information collected about you through our assessments to render recruitment services to our clients.
When you provide us with Personal Information, you will be asked to acknowledge your consent for us to share it with appropriate Clients. This consent is optional and you may withdraw it at any time.
We will explain your options around refusing or withdrawing your consent to the collection, use or sharing of your Personal Information, and we will record and respect your choices. You may decline to provide your consent to the sharing of your personal information. Or, should you provide consent, you may withdraw it at any time.
Disclosure and sharing of Personal Information to Third Parties, Inside and Outside of the EEA:
We will share your personal information with parties outside of the Howitt Partnership Ltd only under the following circumstances:
We will disclose your Personal Information to our clients only with your prior consent.
- When required or permitted by law:
In certain circumstances, the law may require or permit us to disclose your Personal Information without your knowledge or specific consent; for example, such information may be disclosed if required to comply with a subpoena, warrant, or court order, or if requested by a Government institution, which has the lawful authority to obtain the information.
- In exceptional circumstances:
It may be necessary in exceptional circumstances for us to disclose your personally identifiable information as permitted by law or as described above. We will seek to ensure that any proposed disclosure is required in the circumstances, and then ensure that we disclose only the information that is required. Under no circumstances do we sell personal information to other organisations.
- We may from time to time transfer ('transfer' includes making available remotely) personal data to countries outside of the EEA, that the European Commission has determined ensures an adequate level of protection for personal data.
Data Storage and Processing:
We maintain reasonable technical and organisational measures to protect Personal Information from loss, misuse and unauthorised access, disclosure, alteration and destruction. To the extent that we disclose Personal Information to clients or third party service providers, we require that such third parties also maintain reasonable security and confidentiality measures and use the Personal Information in accordance with our instructions and applicable law.
Transmission of information via the internet, however, is never completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account or liaison with us might have with been compromised), please immediately notify us of the problem by contacting us immediately.
We will retain your Personal Information only as long as it is required for the reasons it was collected or as required by law. This period may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your personal information is no longer needed or required, we have procedures to destroy, delete, erase or convert it to an anonymous form.
You have the right to:
- access the personal data which the Howitt Partnership holds about you. This is called a Subject Access Request (SAR) and must be made to the Data Controller whose contact details are provided at the top of this Privacy Notice
- have your personal data rectified if it is inaccurate or incomplete
- request that we remove your personal data
- restrict the processing of your personal data, for example, ask us not to contact you or amend the type of communications you receive
- object to the processing of your data for specific purposes such as communications or direct marketing
- ask for the transfer of your data electronically to a third party (data portability)
- lodge a complaint with the Information Commissioner's Office (www.ico.org.uk).
Our website may contain links to and from partner networks and affiliated organisations. If you follow a link to any of these websites, please note that these websites should have their own privacy policies - we do not accept any responsibility or liability for these policies.
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice.
Implementation and Contact :
This Policy shall be deemed effective as of 25/5/2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
Any questions regarding this Policy should be directed to firstname.lastname@example.org