Silver Swan Search
Last updated 24 July 2020
This privacy notice explains how we, Silver Swan Recruitment Limited of The Ministry, 79-81 Borough Rd, London, SE1 1DN with company number 8367729 (we, us, our) process your personal data (you, your) when you use our website, apps or platforms (services).
Please do not use our services unless you are 16 years old or over.
This notice applies to:
This notice applies to you whether you act in your personal capacity or as employee or agent of an organisation.
Generally, “personal data” refers to any information that identifies you or relates to you. We will process personal data including:
The type of personal data we collect about you will depend on the circumstances and the services you are using.
Generally, we will use your personal data as “controller” to (i) provide our services; (ii) respond to your queries; (iii) develop and promote our organisation and services; (iv) ensure the security and technical availability of our services; and (v) as further described in this notice.
We will update you about any new purposes of processing of your personal data from time to time, and we will obtain your prior consent for such new purposes where we are required to do so at law.
It will be required for you to share information about others, such as your referees, emergency contacts or others within your organisation. You should not provide to us information about others unless you have their permission to do so.
We will likely be unable to assist unless you provide the relevant personal data, and some personal data will be mandatory for our compliance with the law. Nevertheless, you should only provide the necessary personal data to us.
We and our clients will rely on the information provided by you as accurate, complete and up to date, and we shall be grateful if you would inform us of any changes without delay.
5.1 Data about the users of our services
| Purpose | Personal Data | Legal ground for processing |
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To provide our services such as our website, app and platform and features |
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Necessary for our legitimate interest in delivering our services to our users and, where applicable, the performance of our contract with you. |
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To send you information which you have requested about our services and to send you notifications about matters relevant to your use of our services and your engagement with us, such as events, surveys, changes in our terms, etc. |
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Service notifications are necessary for the performance of our contract with you.
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To send you promotional information through various marketing channels including email, social media, telephone, sms, push notification, etc. about our services and our organisation, registering and reviewing campaign performance and profiling your information for direct marketing purposes.
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Where you signed up for our services or marketing, we will send you relevant information based on your consent.
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We will use anonymised information including role, sex, age, salary and other information to create market survey reports and similar materials for statistical and commercial purposes. |
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Necessary for our legitimate interest in understanding the market, informing business decisions, exploring business opportunities and developing and sharing knowledge. |
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To improve and develop our service functionality, including to:
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Necessary for our legitimate interest in delivering our services properly, efficiently and improving our business.
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To ensure proper administration of our business, including to:
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Necessary for our legitimate interest in the proper administration of our business, dispute resolution, ensuring technical operation of our services and debt collection and as is necessary for compliance with a legal obligation to which we are subject.
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To share your information with our third party providers who facilitate the provision of our services and the fulfilment of essential service functions, such as web hosting, cloud storage, analytics, engagement tools, marketing, payment, plugin, communications providers, accounting or security tools and others. |
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Some are necessary for the performance of our contract with you, others are necessary for our legitimate interest in ensuring proper operation of our services. |
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To monitor our networks, systems and services for suspicious activities, fraud prevention, detection and prevention of crime, testing, audit and deployment of security measures, including information from third parties who may alert us about suspicious activities. |
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Necessary for our legitimate interest to ensure the security of our organisation, people and services and in detecting and preventing fraud and illegal conduct and as is necessary for compliance with a legal obligation to which we are subject. |
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To share information within our offices and our group companies. |
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Necessary for our legitimate interest in using our group’s resources to organise, develop and deliver our services, run our organisation and decide on future strategies. |
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To share data with a successor or partner legal entity in compliance with the law for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation or similar event relating to our business. |
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Necessary for our legitimate interest in acting in the best interest of our shareholders and investors and complying with our legal obligations. |
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To process information as is required for our compliance with the law or to establish, exercise or defend legal claims.
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Where processing or sharing your data is necessary for compliance with a legal obligation to which we are subject, to establish, exercise or defend legal claims or, where appropriate and proportionate, in order to satisfy our legitimate interest in complying with best practice or applicable laws. |
5.2 Data about candidates
| Purpose | Personal Data | Legal ground for processing |
|---|---|---|
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See above for information processed about a candidate as a user. |
As above. |
As above. |
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To provide our recruitment services including collecting your information posted on job boards or provided to us, storing your details in our database, assessing your information to find suitable vacancies, facilitating the recruitment process and providing references about you. |
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Necessary for our legitimate interest in delivering our services to our users and, where applicable, the performance of our contract with you. |
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To verify information provided by you, including through third party background screening providers. |
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Necessary for our legitimate interest in maintaining accuracy of information and good standard of service and for fraud prevention or necessary for compliance with a legal obligation to which we are subject.
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To keep a record about career needs and progression while you are our user to offer you relevant services. However, we do not engage in automated decision-making that would significantly affect you. |
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Necessary for the performance of our contract with you, where applicable, and as is necessary for our legitimate interest in providing meaningful functionalities and services. |
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To share information about you with our |
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We will generally share your information on the basis of your consent or, where applicable, for the performance of our contract with you. |
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To assess your career needs and send you notifications about suitable vacancies. |
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Service notifications are necessary for the performance of our contract with you and other notifications are necessary for our legitimate interest in providing meaningful functionalities and services. |
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To process information as is required for our compliance with the law, such as diversity monitoring. |
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Where processing or sharing your data is necessary for compliance with a legal obligation to which we are subject, to establish, exercise or defend legal claims or, where appropriate and proportionate, in order to satisfy our legitimate interest in complying with best practice or applicable laws. |
5.3 Data about our clients, suppliers, contacts and visitors
| Purpose | Personal Data | Legal ground for processing |
|---|---|---|
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See above for processing for the administration of our business. |
As above. |
As above. |
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To assist and contact you in relation to your enquiry. |
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Necessary for our legitimate interest in responding to queries, maintaining business relationships and administering our business. |
We will generally not share your information except with (i) our clients as explained above, (ii) with our third party service providers, commercial partners and group companies for the purposes set out above, (iii) where we are compelled by law, and (iv) other third parties where you have provided your consent.
Although we ask our clients to commit to confidentiality, we cannot be responsible for our clients processing or sharing or your information by other means outside our services.
Our services may contain links to other websites, third party services and plugins. You should check the privacy statements of these third party providers before you use them as we are not responsible for how they may process your personal data.
We will keep your personal data for as long as is necessary for the purposes listed above or longer, as may be required by law. Generally, the retention periods below will apply. You may contact us for further details or request deletion of your personal data at any time.
| Category of personal data | Retention period |
|---|---|
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user details |
1 year following account closure |
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usage data, device & browser data, interaction data |
6 years from collection or 1 year following account closure or end of underlying relationship |
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application data |
Generally, 1 month following successful placement, unless otherwise instructed by you. However, basic education and employment history will be retained same as interaction data. |
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all other personal data |
6 years from collection, unless no longer needed. |
After the retention period, your personal data will either be securely deleted or anonymised and it may be used for analytical purposes. You must back up your data if you wish to keep it for longer.
We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of personal data. We also seek to ensure our service providers do the same.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a personal data breach where required by law.
We will endeavour to use the least amount of personal data as is required for each purpose. We will employ pseudonymisation and anonymisation, where appropriate.
Our staff will access your personal data on a need to know basis.
We may transfer your personal data to our clients, group companies, suppliers and other third parties in countries different to your country of residence. Generally, our data is held in the United Kingdom.
Where we transfer your personal data outside the European Economic Area (EEA) or the UK, we will only do so, where we are satisfied that your data protection rights are adequately protected by appropriate technical, organisational and contractual safeguards in accordance with data protection laws.
We will transfer your information to clients on the basis of performance of contract, where applicable, or your consent. In respect of other third party recipients, we adopt safeguards such as the standard contractual clauses issued by the European Commission or the Information Commissioner’s Office or similar transfer mechanism.
You may request further information on the measures used for the international transfers or access to your personal data from outside the EEA or the UK.
If you would like us to stop sending you marketing communications and to process your personal data for direct marketing purposes, please let us know.
You can stop our communications at any time by clicking on the unsubscribe link at the bottom of the message.
Subject to certain exemptions, limitations and appropriate proof of identity, you will generally have numerous rights in relation to your personal data, including the following:
All requests will be processed in a timely manner, generally within one month. If we cannot process your request within this period we shall explain why and process it as soon as possible thereafter.
Please contact us if you have any queries or concerns about how we use your personal data. You can contact us using the details below. We will try to resolve your query as quickly as we possibly can.
If we make any changes to our notice you will be able to see them on this page. You should regularly check for updates, as indicated by the “Last updated” date at the top.
If you do not agree to the changes, please do not continue to use our content or services. Of course, if any such changes significantly affect you, we will ask for your prior consent where required by law.
