EA – Privacy Notice
Executive Action Ltd. (EA) is a career consultancy company for senior executives. We do not knowingly attempt to solicit or receive information from children.
We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Notice describes EA’s policies and practices regarding its collection and use of your personal data, and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.
What we need
EA is headquartered in London, in the United Kingdom. EA will be what’s known as the ‘controller’ of the personal data you provide to us. We collect basic personal data about you which does not include any special categories of data.
If you are/were a client of EA, your basic personal data includes contact history, name, address, email, phone number, employment history, qualifications, programme details, psychometric tests, CVs and the like. If you are a (networking) contact of EA, we process your basic personal data, which includes name, address, email, phone number, previous and current employment details, and the like.
If you are an employee of EA, we process your basic personal data, which includes name, address, email, phone number, previous and current employment details, qualifications and the like. We also process your sick leave details that is identified as a special category of data.
Why we need your data
If you are a client of EA, we need your basic personal data in order to deliver the contract we agreed with you. We will not collect any personal data from you we do not need in order to provide and oversee this service to you. We will ask you to sign a consent form to enable us to send you relevant news, event invites, and the like, should you wish to hear about such information.
If you are a (networking) contact of EA, we need to know your basic personal details to enable us to personalise the information we send you as part of our marketing communication (legitimate interest).
If you are an employee of EA, we need to know your basic personal data to fulfil our contractual obligation with you. Additionally, as an employer, EA is required by law to pay tax and pension, if applicable, for its employees. To satisfy this legal duty, EA have to keep records of employer’s data and share them with third party that deliver these services on EA’s behalf. Your sick leave details are recorded to monitor absence and to establish possible sick pay. We process this information as part of your employment with EA.
What we do with your data
EA collects personal information about its clients and other contacts. All the personal data we process is processed by our staff in the UK, however for the purposes of IT hosting and maintenance this information is located on servers internationally. No 3rd parties have access to your personal data unless the law allows them to do so. We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of EA services.
EA will use your personal information for a number of purposes including the following:
- provide our services, activities or online content, to provide you with information about them and to deal with your requests and enquiries;
- to provide you with the most user-friendly online navigation experience;
- to use IP addresses and device identifiers to identify the location of users, to block disruptive use, to establish the number of visits from different countries, and to determine whether you are accessing the services from the UK or not;
- we may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
If you correspond with us by email, the postal service, or other form of communication, we may retain such correspondence and the information contained in it and use it to respond to your and the like. If you wish EA to erase your personal information or otherwise refrain from communicating with you, please contact us at email@example.com
Note: if you ask EA not to contact you by email at a certain email address, the EA may retain a copy of that email address on its “unsubscribe” list in order to comply with your no-contact request.
We strongly encourage you not to submit any type of payment card or login information by email. When EA employees receive such information from clients or contacts by email, phone, or mail, it is entered as instructed and then deleted or destroyed.
We have a Data Protection regime in place to oversee the effective and secure processing of your personal data. More information on this framework can be found in our Data Protection Policy which is available on request, please contact firstname.lastname@example.org to obtain a copy.
Use of the executive-action.com website
As is true of most other websites, EA’s website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of the EA’s website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyse trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.
Please note that during your visits to EA websites you may notice some cookies that are not related to EA. To enable you to share EA website content easier, we sometimes offer social media sharing buttons. These may include YouTube, Google Plus, Twitter, Facebook, Instagram, Pinterest and Flickr. As a result, when you visit a particular social media page, you may be presented with cookies from these websites and these third party cookies may track your use of the EA website. EA does not control the dissemination of these cookies and you should check the relevant third party’s website for more information. If you continue without changing your settings, we’ll assume that you are happy to receive all cookies on the EA website. However, you can find out about changing your cookie settings here (link to BBC information site).
When and how we share information with others
Information about your EA programmes are maintained in association with your client account. The personal information EA collects from you is stored in one or more databases hosted by third parties located internationally. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval.
We do not otherwise reveal your personal data to third-parties for their independent use unless:
(1) you request or authorise it;
(2) it’s in connection with EA-hosted and EA co-sponsored events;
(3) the information is provided to comply with the law (for example, to comply with a search warrant, subpoena or court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others;
(4) the information is provided to our agents, vendors or service providers who perform functions on our behalf;
(5) to address emergencies or acts of God; or
(6) to address disputes, claims, or to persons demonstrating legal authority to act on your behalf.
Transferring personal data from the EU internationally
EA has its headquarters in the United Kingdom. Information we collect from you we process in the United Kingdom to perform a contract with you; or to fulfil a compelling legitimate interest of EA in a manner that does not outweigh your rights and freedoms. EA works with data processors that store the hosted information in one or more databases hosted by third parties located internationally. EA endeavours to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with EA and the practices described in this Privacy Notice. EA also minimizes the risk to your rights and freedoms by not collecting or storing special category of information about you.
How long we keep your data
Personal data will be held for as long as the individual is a client of the company plus 6 years. We are required under UK tax law to keep your basic personal data for a minimum of 6 years after which time it will be destroyed. Your information we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information. More information on our retention schedule can be found in our Data Retention Policy.
If your details are processed as a (networking) contact of EA, we will keep your records as long as our communication is relevant to you unless you request to be unsubscribed from the mailing list.
General employee data will be held for the duration of employment and then for 6 year after the last day of contractual employment. Employee contracts will be held for 6 years after last day of contractual employment.
What are your rights
The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects. A clear explanation of them is available on the website of the United Kingdom’s Information Commissioner’s Office.
This Privacy Notice is intended to provide you with information about what personal data EA collects about you and how it is used. If you have any questions, please contact us at email@example.com
If you wish to confirm that EA is processing your personal data, or to have access to the personal data EA may have about you, please contact us at firstname.lastname@example.org
You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside EA might have received the data from EA; what the source of the information was (if you didn’t provide it directly to EA); and how long it will be stored, existence of automated-decision making.
You have a right to correct (rectify) the record of your personal data maintained by EA if it is inaccurate. You may request that EA erase that data or cease processing it, subject to certain exceptions. You may also request that EA cease using your data for direct marketing purposes. You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how EA processes your personal data. When technically feasible, EA will – at your request – provide your personal data to you.
Reasonable access to your personal data will be provided at no cost to EA clients and contacts and others upon request made to EA at email@example.com
EA will not charge when the first access is requested, although a ‘reasonable fee’ may be charged for multiple or excessive requests.
EA aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 30 days. EA must verify the individual’s identity prior to granting access to information. The information will be provided in commonly used electronic format.
Security of your information
To help protect the privacy of data and personally identifiable information you provide us with, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. In addition, we train our employees on the importance of confidentiality and maintaining the privacy and security of your information.
Data storage and retention
Your personal data is stored by EA on the servers of the cloud-based database management services we engage located internationally. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact EA at firstname.lastname@example.org
Questions, concerns or complaints
Alexandra Pack – Marketing & Research Manager,
Executive Action Ltd – 10 Fitzroy Square, London W1T 5HP
E: email@example.com T: 020 7859 4892
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office.