Client and Candidate Data Protection Policy Overview

Introduction

Aspen is committed to protecting the privacy of personal data. This statement summarizes our policy regarding the collection, use and transfer of personal data, the security measures we employ to protect such data and your rights in relation to it.

The Information We Collect

Aspen is a leadership advisory and executive search firm which collects, uses and stores a variety of personal data necessary to provide such services.

-Executive Search Data

If you are a potential candidate for one of our executive search assignments, categories of personal data we collect may include: contact information (e-mail address, address, telephone number), career history, education history, social activities, compensation details (where permitted by applicable legislation), professional experience, languages, photographs, individual capabilities and preferences, personality, character traits, professional style profile, executive competencies, interview notes (if applicable), identification data (civil/marital status, gender, nationality), and contact history. This data may be obtained directly from you, through publicly available sources and/or third parties such as sources/referees, your professional networking profile, news reports and our authorized background check providers.

It is not our policy to seek any sensitive information about you unless done for legitimate recruitment purposes and we suggest that you do not provide information of this nature unless required.

-Leadership Consulting Data

If you participate in one of our Leadership programmes or are assessed as part of our services, we may collect information such as your name and email address, qualifications, work experience, psychometric and cognitive assessment findings, details regarding your employment, responsibilities at work, your professional views and opinions, as well as any other information and responses you may provide to evaluative measures and interviews. Providing additional personal data such as age, gender, and ethnicity is voluntary and has no influence on the assessment results.

-Referee or Source Data

If you are an individual who provides a personal reference or feedback for a candidate, we may collect and process your contact details, certain professional details (such as title, occupation, qualifications and employment history) and your connection to the candidate. We may collect this information directly from you, the candidate or from publicly available sources. We will use this information to gather information on the relevant potential candidate such as your connection to, experience with, and opinion about such potential candidates. Any reference or feedback you provide about a candidate would not be attributed to you if shared with third-parties. We may also use your contact details to contact you in relation to any of our services that we believe may be of interest to you.

-Client or Supplier Data

If you are an Aspen client or supplier, we will collect and use information about your company and individuals within your company for the purposes of fulfilling our obligations to you and furthering our business relationship. Data collected will typically comprise your contact details (such as name, telephone number, email address, job title, and business record related to our services).

We may also use the data for other business purposes, including data analytics, benchmarking and statistic purposes. We may use the personal data collected to contact you in relation to any of our services that we believe may be of interest to you.

Where Personal Data is Held

Personal information collected is held on Aspen’s database which is hosted in the UK and is subject to all prevailing UK and EU law. This database is accessible to Aspen staff only and can be accessed only over secure and encrypted connections, worldwide.

How We Use Personal Data

We will not process your personal information in a way that is incompatible with what is outlined in this Privacy Policy, and will use our best efforts to ensure that data is accurate, complete, current and reliable for its intended use.

Candidate and Assessment Data

The data is used in the usual course of our business to provide our services to clients. This may include assessing your suitability for executive and non-executive roles, presenting you as a potential candidate to potential employers (Aspen’s clients), contacting you for an assignment (executive search or assessment) or verifying the details of your profile.

Your personal information may also be shared with third parties who we have engaged to provide services such as education checks and/or background checks, to the extent that the checks performed are appropriate and in accordance with local legislation, as well as our third party service providers who perform functions on our behalf such as outsourced document storage providers, all of whom will be required to process your personal information in accordance with applicable data protection laws and this Privacy Policy. Your personal information may also be shared with Referees or Sources in order to obtain additional information about you so we can provide a more accurate profile to our clients.

Finally, your information may also be shared with any competent law enforcement, regulatory or governmental body, or a court of law if necessary to exercise our legal rights, protect your interests or as a matter of applicable law.

Intellectual Capital

We may contact you from time to time to share intellectual capital and thought leadership that we have published when we believe it could be of interest to you or relevant to your role at your organization. You may opt out of receiving these at any time.

Convening

From time to time we may contact you with an invitation to attend an industry- or role-specific event, such as a dinner or charity event. You may opt out of receiving these invitations at any time.

Legal basis for processing your personal information

Aspen’s legal basis for collecting and using the personal information described in this policy will depend on the personal information involved and the context in which it was obtained.

We will process basic personal information from you, such as your contact details (name, address, email, phone number) and information that would normally be included in a curriculum vitae (education history, employment history, professional experience, compensation history where permitted by local law, etc.), and competencies, as well as any additional information that may assist us in connecting you to an executive search assignment (such as professional interests or relocation interest) or data that we may have obtained in the context of our leadership advisory services, on the basis of legitimate interests, provided the processing of such information is not overridden by your own privacy interests or your rights and freedoms as provided by law.

Once we proceed to further stages of the search process, we may ask you to sign a consent form for additional processing activities, such as additional information that may come to light during the search process, information you may provide during interviews, information obtained through the use of our proprietary assessment techniques and tools, sensitive personal information (should you decide to voluntarily share this) as well as any insights that we may provide to our clients.

If you require any further information concerning the legal basis on which we process your personal information, you may contact us at info@aspen-worldwide.com.

Information Security and Integrity

To prevent unauthorized access, maintain accuracy of data and ensure proper use of information, Aspen has implemented appropriate legal, physical, technical and security procedures to protect the confidentiality of and safeguard the personal information collected, and prevent against accidental loss, unauthorized access, or unlawful processing. These measures will be reviewed over time and upgraded to remain up to date with legal and technological developments.

Retention

Aspen will retain your personal data only for as long as the data is needed in connection with the purposes for which is it being collected and used. The following criteria will be used to guide us when retaining your information:

• We will retain personal data for as long as we maintain an active relationship with you;
• Once our relationship with you has ended, your personal data may still be relevant for our current or future legitimate business purposes, for example we may be required to retain certain personal information for our business records if you have been placed into a role by us, or for us to be able to establish, exercise or defend our legal rights;
• Certain data may be required to be kept in order to show we are compliant and have fulfilled our obligations towards our clients or to continue meeting any obligations we may have once we have completed an assignment for our clients in which you may have been involved.

Your Rights

You have the right to access, erase, correct, update or complete your personal data, to request the transfer of your personal data to a third party, or to request no further contact from Aspen. Additionally, you have the right to object to the processing of your personal information, ask us to restrict processing of your personal information, request transfer of your personal information to a third party, or to withdraw your consent at any time. If you wish to exercise any of these rights you may contact info@aspen-worldwide.com.

Should you request that we remove your personal information from our database, please note that we may retain a minimal amount of personal information about you in order to prevent future contact, record your wish for your data to be removed, and to keep a record of the information disclosed to our clients.

Similarly if we have collected and processed your personal information on the basis of your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect any processing performed prior to your withdrawal nor will it affect processing on the basis of lawful processing grounds other than consent.

Finally, you have the right to bring a complaint to the relevant data protection authority in your jurisdiction about our collection and use of your personal information. For more information on how to lodge a complaint, please contact your local data protection authority.

Material Changes to the Privacy Policy

Aspen reserves the right to modify or amend the Privacy Policy at any time and for any reason. If there are material changes to the Privacy Policy, we will post those changes here and take appropriate measures to keep you informed. Please check back to this Privacy Policy from time to time to stay informed.

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