Company Details

Constellate Global Talent Limited
Registered office: registered in England and Wales: 3 Wellbrook Court, Cambridge CB3 0NA
Company registration number 14358152

This policy covers the collection, processing and other use of personal data under the Data Protection Act 2018, and in compliance with the General Data Protection Regulations (GDPR), for which purpose the data controller is Constellate Global Talent Ltd.  

We are registered with the Information Commissioner’s Office for this purpose (registration number 00011353442).

Constellate Global Talent Limited is a boutique consultancy firm, registered in the UK,  that offers services to not-for-profit organisations to transform their talent management programmes. 

We are committed to maintaining your confidence and trust with respect to your privacy. Our principles are simple – we will be transparent about what data we are collecting about you, the sources of that data, how we use the information we hold about you, and the choices you can make.  

Introduction

All organisations that process personal data are required to comply with data protection legislation.  This includes in particular the UK’s Data Protection Act 2018 (or its successor), the UK and EU General Data Protection Regulations, and the Privacy and Electronic Communications Regulations (together the ‘Data Protection Laws’).  The Data Protection Laws give individuals (known as ‘data subjects’) certain rights over their personal data whilst imposing certain obligations on the organisations that process their data. All organisations that process Personal Data have a legal duty to ensure that this personal information is collected and used fairly, stored safely and not disclosed to any other person or organisation unlawfully.

This Privacy Policy is provided by Constellate Global Talent Limited (“we”, “our” and “us”) and is for individuals outside our organisation with whom we interact. This includes, but is not limited to, Candidates, Clients, Sources and visitors to our website (“you”).

As a Talent Management Consultancy, we collect, process and store certain Personal Data and Sensitive Personal Data, for example about Clients and Candidates, in order to fulfil our commercial purposes.  We are required to do so to comply with other legislation.  We are also required to keep this data for different periods depending on the nature of the data.

This Privacy Policy sets out how we collect and process your Personal Data in our dealings with you and implement the Data Protection Laws. It should be read in conjunction with any other privacy statements or fair processing notices we may provide on specific occasions when we are collecting or processing Personal Data about you.

You have control over the data we collect on you and are free to decline to provide Personal Data. If you choose not to provide data that we deem necessary, however, we may not be able to assist you in work-finding services (if you are a candidate), or we may not be able to fulfil our obligations to you (if you are a client).  We will be clear on what information we require and why, so that you can choose accordingly.

This website may include links to third-party websites (e.g. belonging to our Clients). Clicking on those links or enabling those connections may allow these third parties to collect or share data about you. We do not control these third-party websites, nor are we responsible for their privacy statements and activities.  We recommend that you read the individual third-party websites’ privacy statements if you are concerned.

We collect personal data on our candidates, clients, their employees and our other contacts for the purposes of maintaining our relationship with them and fulfilling our contracted role. 

Lawful basis for processing

We rely on legitimate interest as the lawful basis on which we collect and use your personal data. Our legitimate interests are delivering talent management services.

Information we collect

We collect information from you in three ways: directly from you during your ongoing relationship with us, from your employer, or from publicly available sources, such as LinkedIn. The amount of data we collect depends on the frequency and nature of your interactions and engagement with us. 

If you proceed with a job application, or should we consult you about a role, you may be required to submit additional personal data. For example, your curriculum vitae (CV), or resume. Your CV or resume may contain employment history, education, professional qualifications, memberships, details of papers written, references and referees, amongst other things that you choose to include. We may therefore hold and process the following types of personal data about you as a result of you sharing your CV, resume or supporting statement: 

  • Personal details: your names (given and preferred); date of birth or age; nationality; marital status; job title; employer; department; salary and compensation details; and where applicable, your passport number and photo, visa number, or work authorisation number.

  • Contact details: home address; telephone numbers; personal and/or email address; and social media profile details (e.g. LinkedIn).

  • Employment records: dates and details of current and former positions held; details of current and former employers; dates of employment; job titles; job locations; subject matter experience; and details of any employment disciplinary issues or incidents declared.

  • Details of your referees: details of referees you may provide, including their contact details, how long you’ve known them and in what capacity.

  • Background checks: details revealed by background checks conducted in accordance with applicable law and subject to your prior express consent, including your identity, and details of your previous employment and residence.

  • Views and opinions: your views on Candidates, Clients or other third-parties, where relevant and applicable.

  • Publicly available profile pictures, where copyright allows, e.g. a photo of you from your LinkedIn profile or company website

  • Links to your public social media presence, e.g. LinkedIn, Twitter, website or blog

  • Records of your personal interactions with us, e.g. correspondence, notes of meetings or conversations

  • Your communication preferences

  • Records of communications you have received from us, incl. copies of letters or emails sent, and of marketing activities in which you have been included 

  • Information about how you interact with our email communications

  • Your relationships with other of our contacts, e.g. work colleagues

  • Information about current or past projects we have worked on with you, or enquiries you have made to us

  • Plans for activities, future interactions and next steps

  • Records of any thank you gifts we have sent to you.

  

How we use your data

  • To deliver Talent Management Services, we use research systems, online databases and other information sources such as LinkedIn, and talk to many individuals. These will include references and sources to help inform our decision-making process. 

  • We collect information from candidates directly when you send us your CV or resume to us via email or post. We also collect information from you when you speak with a Constellate employee in any office around the world.  This information is collected and stored on Sharepoint.

  • We use the personal data we collect from you to process job applications, in partnership with our clients, on whose behalf we are instructed to help fill a job vacancy. This means that if you apply for a specific job, we may pass your details to the relevant client to proceed with the application. As a result, you may receive further direct correspondence from them.

  • Administration and processing of Candidates’ Personal Data for the purposes of providing work-finding services, including processing using software solution providers and back office support. This includes providing work-finding services to you including our website facilities and other services; attending meetings and/or telephone/video calls with you; supporting you in preparing for interviews, and otherwise communicating with you in relation to those services.

  • Administration and processing of Clients’ personal data for the purposes of supplying/introducing Candidates. This includes recruitment activity and providing these services to our Clients; advertising Client opportunities; supporting Clients to understand which Candidates are interested in their opportunities; record-keeping; and performing background checks.

  • Administration and processing of industry contacts’ (such as fundraising consultants, etc.) Personal Data for the purpose of making relevant business introductions as requested by Candidates or Clients, and on agreement of the contact.

  • Improving our services and offerings through identifying issues with existing services; planning improvements to existing services; and creating new services.

In pursuit of our business interests, we use personal data to manage our relationship with candidates, clients, potential candidates and potential clients, deliver our services, and to send news of interest about our firm and its services, and about broader areas of interest to clients. We may do this by post, telephone or email. Those who provide us with email addresses will be sent our e-news from time to time. We may, on occasion, use an email provider, such as Mail Chimp, to send e-marketing. Each newsletter contains an unsubscribe option and we can also remove you from the list if you send a request to our head office whose contact details are below.  

Please be aware that we are not responsible for the data processing activities of others, such as our clients. 

When and how we share your data

We may, from time to time, need to share your information with third parties working on our behalf, for example associate consultants. We only do this in appropriate circumstances, by secure means, and with the relevant appropriate data sharing agreement in place before sharing your personal data. We do not, and will not, sell your data. 

Transferring your Personal Data internationally

Due to the international nature of our business, offices and Candidates’ international career aspirations, we may need to share your Personal Data with other Constellate Global Talent associates, as well as third parties as noted previously in connection with the purposes set out in this Policy. For this reason, we may transfer your personal data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. We implement appropriate technological and organisational measures to prevent the unlawful discourse of Personal Data and transfer data as permitted in accordance with the Data Processing Legislation via intra-company transfer.

How we protect your personal data

We take the security of your data very seriously. We take precautions to safeguard your personal information against loss, theft and misuse, unauthorised access, disclosure and destruction through the use of appropriate administrative, physical and technical security measures.  

Keeping information secure

We invest significant resources to protect your personal data, from loss, misuse, unauthorised access, modification or disclosure. However, no system can be 100% secure, and so we cannot be held responsible for unauthorised or unintended access that is beyond our reasonable control. 

How long we keep your data

As an executive search firm, we rely heavily on the personal relationships we build with Candidates, Clients and third parties. We will therefore hold personal data relating to Candidates and Clients for a certain period of time in order to remember you and the nature of your previous interactions with our firm.

We will hold your personal data for six (6) years following your last contact with us. We have determined that this is a reasonable period, given the average job tenure and movement for individuals. 

Please note that if we have assisted you by providing work-finding services in the last twelve (12) months, we are obligated to retain your records for at least a year from when we last assisted you, by the Conduct Regulations of the Recruitment & Employment Confederation (our industry body).

The legal basis for processing your data

Constellate Global Talent Limited is the Data Controller for the personal data we hold on you. 

We rely on three grounds for lawful processing: 
For the purpose of administering contracts with clients, to the extent that we process personal data we do so because it is necessary for the administration of a Contract.

For our marketing, executive search, recruitment and any other promotional activity we process data because it is in our Legitimate Interest to communicate with candidates and clients.

Where we are communicating with you via your personal email address rather than a company email address, we rely on your Consent to do so. You can withdraw this consent at any time. 

We are registered with the ICO (registration number 00011353442) as a Data Controller. 

Your rights

You have a number of rights in respect of your data:
If we are processing data with your consent then you have the right to withdraw that consent without prejudice.

If we are processing data because it is in our Legitimate Interest to do so then you have the right to require us to stop such processing.

You have the right to request a copy of any data we hold about you or to request that we correct any incomplete or inaccurate date.

You have the right to request the transfer of your data to another party.

You have the right to complain about the way in which we process your data. Contact details for this are below.

You also have the right to complain to the Information Commissioner about the way in which we have processed data. Contact details are at: www.informationcommissioner.org.uk

Cookies

Cookies are text files containing small amounts of information that are downloaded to your device whenever you visit any website (including ours) that makes use of them. This information is then sent back to the originating website on each subsequent visit, or to another website that recognises those cookies. They are used for multiple purposes, such as letting you navigate between pages efficiently, remembering your preferences, and generally improving your web site experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.  We may process your Personal Data through cookie technology, in accordance with our Cookie Policy.

Contact details

Contact us with any queries about your data or this Privacy Policy at:

Data Protection Officer 

Constellate Global Talent

3 Wellbrook Court

Cambridge CB3 0NA

Email: info@weareconstellate.com

Changes to this Privacy Policy

We reserve the right to update this Privacy Policy at any time. Any changes to this Privacy Policy will be posted to our website. 

April 2024