FWB Park Brown Ltd. and its affiliate FWB Park Brown Inc. (collectively “FWB Park Brown”) is an Executive Recruitment Company which advises and supports our clients to identify and recruit Board level (Non-Executive and Executive (c-level)) and Senior Management talent.
We are committed to ensuring that your privacy is protected throughout this process.
How do we collect information about you?
There are three primary ways in which we would collect your personal data:
- Directly from you;
- An exchange of data between affiliates FWB Park Brown Ltd. in the U.K. and FWB Park Brown Inc. in the U.S.; and
- From third parties.
Personal data we collect directly from you
There are numerous ways you can share your information with us, including:
- Applying for jobs directly through the FWB Park Brown website;
- Providing your CV to an FWB Park Brown employee or being interviewed by them; and
- Applying for jobs through a specially identified third party job portal, which may in some cases then redirect you to the FWB Park Brown website.
Personal data we receive from third parties
We also receive personal data from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these include personal data received in the following situations:
- Information about you from searching for potential candidates from third party sources, such as LinkedIn, other job sites and the wider internet (including company websites and news articles);
- If you ‘follow’ us on Twitter we will receive your personal information;
- Your referees disclose personal information about you; and
- Our client shares personal information about you with us.
If we have received your details from a third party source we will confirm the source through which this information was received should we contact you.
What information do we collect about you?
FWB Park Brown processes personal data in the course of the process of providing our services.
We collect and use (process) the following personal data in relation to individuals who are being assessed for recruitment by third party employers:
- Contact Details
- Employment Details
- Where applicable, psychometric test results
We collect and use (process) the following personal data in relation to our clients:
- Contact Details
We collect and use (process) the following personal data in relation to our suppliers:
- Contact Details
How will we use the information about you?
FWB Park Brown will only collect and process personal data that is necessary for the purpose or purposes that we have identified in advance. We will use your personal data for the below purposes if we deem it necessary to do so for our legitimate interests or if we have contracted with you. Please note that this list is not exhaustive.
- Storing your details (and updating them when necessary), so that we can contact you in relation to recruitment;
- Providing you with our recruitment services and to facilitate the recruitment process;
- Assessing data about you against vacancies which we think may be suitable for you;
- Sending your information to clients, in order to apply for jobs or to assess your eligibility for jobs;
- Carrying out our obligations arising from any contracts entered into between you and FWB Park Brown;
- Carrying out our obligations arising from any contracts entered into between FWB Park Brown and third parties in relation to your recruitment;
- Facilitating our payroll and invoicing processes; and
- Verifying details you have provided, using third party resources (such as psychometric evaluations or skills tests), or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws).
Otherwise, we may process your personal data for the purposes of complying with our legal obligations; in connection with the detection of crime or the collection of taxes or duties; and for the establishment, exercise or defence of legal claims. Where you have entered into a contract with us, failure to provide personal data may mean that we are unable to properly implement the contract and that you are unable to exercise certain contractual rights.
Our Legal Bases for Processing your Data
Where data is processed in the United States, we will collect and process your data in compliance with applicable US state and federal law. Where the General Data Protection Regulation applies, we will only process your personal data where we have a lawful basis for processing as set out in Article 6 of the General Data Protection Regulation (GDPR).
The personal data we hold about you is processed by us on the basis of our legitimate interests to gather and review publically available professional information about you for the purposes of identifying potential suitable candidates for management and board level positions, which is not outweighed by any detriment to you.
Where you have engaged with us in the recruitment process your information will be processed on the basis of your contract with us to provide you the services.
How long will we store your data for?
We will delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for seven years.
Disclosure of Your Data
In order to deliver our services to you, we share your information with third parties, in particular, your prospective employer. FWB Park Brown Ltd and FWB Park Brown Inc. share your information with each other for the purpose of conducting FWB Park Brown business. This involves the transfer of personal data to the United States. All information and personal data which is transferred out with FWB Park Brown shall be stored securely and treated as confidential.
To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.
We also occasionally share your data with other organisations such as law enforcement or other agencies where required by law; in our opinion such action is reasonably necessary to comply with legal process; to respond to any legal claim or actions; or to protect our rights, our service user’s rights or the general public.
Notice to California USA residents
We do not disclose a user’s personal data to any third-party for such third-party’s direct marketing purposes. Thus, under California Civil Code Sections 1798.80-1798.84, FWB Park Brown has no obligation to a California resident to provide further information regarding FWB Park Brown’s use of the California resident’s personal data.
Notice to Utah USA residents
We do not disclose a user’s personal data to any third-party for such third-party’s direct marketing purposes.
How do we store and transfer your data internationally?
FWB Park Brown will not transfer any personal data to a country outside the EU or an international organisation without ensuring the level of protection provided by applicable data protection laws is not undermined.
We will only carry out international data transfers of your personal data to a country outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where the recipient is compliant with EU data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
- by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EU to data controllers and processors in jurisdictions without adequate data protection laws; or
- by certification that the recipient is registered and compliant with the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or
- transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation.
We may also undertake a transfer:
- where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are our client); or
- where you have expressly consented to the data transfer.
For US residents, your data may be transferred internationally to the EU or to other non-EU countries:
- between and within the FWB Park Brown entity located in the United Kingdom;
- to third parties (such as advisers or other suppliers to FWB Park Brown);
- to overseas clients; and
- to a cloud-based storage provider.
Access to your information and correction
FWB Park Brown will ensure that is has procedures in place to allow you to exercise the following data subject rights under the GDPR:
- Subject Access
- Restriction of processing
- Data Portability
- Object to processing
- Object to automated decision making
If you wish to exercise any of these rights or for further details please contact us for a copy of our Data Protection Policy at email@example.com
For further information about Privacy Shield participants please see the US Department of Commerce Privacy Shield List at www.privacyshield.gov/list.
Resolving Your Complaints
In compliance with the Privacy Shield principles, FWB Park Brown commits to resolve complaints about our collection or use of your personal data. If you have an inquiry or complaint regarding this Privacy Shield Policy, please contact FWB Park Brown at firstname.lastname@example.org.
We are committed to refer unresolved Privacy Shield complaints to the panel established by the EU data protection authorities. If the dispute involves personal data collected in the context of an employment, agent, or sub-contractor relationship, we will also cooperate with competent EU data protection authorities and comply with advice of such authorities. In the event that we or such authorities determine that we did not comply with the Privacy Shield requirements, we will take appropriate steps to address any adverse effects and to promote future compliance. Further, any of our employees who are found to have violated the Privacy Shield Policy will be subject to disciplinary process. If your complaint is not resolved to your satisfaction please go to www.ico.org.uk/make-a-complaint/eu-us-privacy-shield/ to make a complaint at no cost.
In certain circumstances, you may invoke Privacy Shield arbitration if your complaint has still not been resolved. For further information please see www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.
Where you access and use the FWB Park Brown website we will also collect website usage information using cookies.
When someone visits our website we use a third party service, Google Analytics, to collect standard, not personally identifiable, internet log information and details of visitor behaviour patterns.
For further details please contact us for a copy of our data protection policy at email@example.com
Use of data processors
Data processors are third parties who provide elements of our service for us (cloud based storage providers, and software providers). We have contracts in place with our data processors which require all information and personal data which is transferred by FWB Park Brown shall be stored securely and treated as confidential. Data processors will hold it securely and retain it for the period we instruct. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us.
How to contact us
We are committed to ensuring that your personal data is processed lawfully, fairly and securely. If you have any questions or concerns about this notice or the way in which we process your data please contact us:
For EU or UK residents:
by email: firstname.lastname@example.org
GDPR Team, FWB Park Brown, 19 Alva Street, Edinburgh, EH2 4PH
For US Residents:
by email: email@example.com
GDPR Team, FWB Park Brown, 25700 I-45 North, Suite 400, The Woodlands, Houston, TX 77386
Right to lodge a complaint
If after contacting us you remain unsatisfied you can contact the Information Commissioner’s Office (ICO) at:
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Phone: 0303 123 1113