Who are we?
We are Sam Ferris Associates Ltd. We provide executive search services to clients looking to recruit personnel for their businesses. We also provide coaching services for candidates.What does this Policy cover?
We at Sam Ferris Associates take your personal data seriously. This policy:
What personal data do we collect about you?
- sets out the types of personal data that we collect about you
- explains how and why we collect and use your personal data
- explains how long we keep your personal data for
- explains when, why and with who we will share your personal data;
- sets out the legal basis we have for using your personal data;
- explains the effect of refusing to provide the personal data requested;
- explains the different rights and choices you have when it comes to your personal data; and
- explains how we may contact you and how you can contact us.
We collect the information necessary to be able to find available opportunities and further information needed to assess your eligibility through the different stages of recruitment. This information includes CV’s, identification documents, educational records, work history, employment and references.
We may also collect sensitive personal data about you, in the form of passport information. We only collect sensitive personal data from you, and further process this data, where you have given your explicit consent.
If you are receiving coaching from us, we will also process any additional information that you choose to provide to us during the course of the coaching.Where do we collect personal data about you from?
The following are the different sources we may collect personal data about you from:
How and why we use your personal data?
- Directly from you. This is information you provide while searching for a new opportunity and/or during the different recruitment stages [or coaching, where relevant].
- From an agent/third party acting on your behalf. e.g. Interim Management Company.
- Through publicly available sources. We use the following public sources:
- Internet searches
- 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.
We use your personal data to match your skills, experience and education with a potential employer. We will initially collect basic information on you such as contact details, job role and experience and then pass this on to the client in search of personnel. If you are chosen by the client and go through to the next stage we will then be collecting more information from you at the interview (or equivalent) stage and onwards in that manner.
[If you are receiving coaching from us, we use your personal data in order to understand more about you and to assist you with understanding your skills and areas for improvement or future opportunities and options.]How long do we keep your personal data for?
We keep your information in accordance as follows:
Who do we share your personal data with?
- Candidate data: Reviewed every 6 years
- Client contact details: Reviewed every 6 years
Your personal data is shared with the client who initiates a search for personnel. The search for which you are considered, to ascertain if you are a good fit for the available position.What legal basis do we have for using your information?
For prospective candidates, interim managers, referees and clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees.
If you are shortlisted as a candidate [or if you are coached by us], then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case we always ask for your consent before undertaking such processing.
For clients, we may also rely on our processing being necessary to perform a contract for you, for example in contacting you.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 data necessary, or withdraw your consent for the processing of your personal data, we may not be able to match you with available job opportunities.Do we make automated decisions concerning you?
We may make automated decisions about you during the assessment stage of the recruitment process. We put assessment candidates through a structured screening process to assess whether each candidate meets the specific criteria for a particular position. These assessments may be fully automated e.g. online pre-screening tests. As these assessments may result in a candidate being deemed not suitable for a position by means of a solely automated assessment, we only undertake this activity with the candidate’s explicit consent. We also carry out personality profiling on candidates with the candidate’s consent.Do we transfer your data outside the EEA?
No, we do not transfer personal data out of the EEA.What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.Rights
- 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.
- The right of access
- 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 data 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 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 lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
- The right to withdraw consent
If you have given your consent to anything we do with your personal data, 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 data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data 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, or
- 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.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.How can you contact us?
A “cookie” is a software application that enables us to track and store information about the use of our websites and services. Cookies do not harm your computer.
By using our website you are agreeing to the placement of cookies on your computer.
You can find out more about the way cookies work here
This page sets out our initial Cookie Law compliance policy as of 25th May 2018.
In addition to publishing this new website page, we will continue to monitor the compliance advice and guidance issued by the Information Commissioners Office (ICO) and aim to address all compliance aspects required by the regulations, whilst continuing to making it easy for visitors to our website to access all of the information available.
Apart from the publication of this new page and policy, the operation of our websites has not been modified.
The purpose of publishing this policy is to allow you to make an informed choice about your continued acceptance of cookies as you use our websites.
Cookies are small text files that are used on almost every website that you will visit. They are saved on your computer to help the site perform a number of functions for visitors and site users.
You can usually use your browser to manage cookies through the browser settings. You may be able to choose to disable cookies completely. You may also be able to choose to delete existing cookies, to stop your browser accepting new cookies and you may be able to set your browser to notify you when you receive a new cookie.
By using our website you are agreeing to the placement of cookies on your computer.
Sam Ferris Associates Ltd
Registered in England and Wales, Company No. 09158828
Registered Office: 35 Christchurch Street East, Frome, Somerset, BA11 1QH