/ GDPR Policy
INTRODUCTION TO THIS POLICY
Needless to say, CloseTheGap is responsible for all Personal Data (see definition below), which we are processing as a firm. We are fully committed to the privacy of any information provided to us by you. As a firm, we have relevant systems in place to prevent unauthorised access or disclosure of your Personal Data and we continuously train our personnel in the management of Personal Data. This Policy outlines our current practices as regards Personal Data gathered by us from you directly and/or through third parties.
The term ”Personal Data” (also referred to as ”Data” below) refers to personally identifiable information about you, such as for example your name, personal identification number, address, phone number, email address and other contact information together with any other information which is linked directly or indirectly to you.
The terms ”you”, ”your” and ”yours” in this Policy refers to you in your role as candidate, client or other stakeholder in relation to CloseTheGap. Needless to say, CloseTheGap may have various purposes for collecting personal data, depending on whether you are interacting with CloseTheGap as a candidate, client or as a so-called other stakeholder. Please however note that you may also quickly move between the three different groups as our way of conducting business means you can potentially e.g. quickly move from the role as a candidate into the role as a client. Normally, we strive to collect more information about you if you interact with us in the role as a candidate in comparison to a client and other stakeholders. We always strive to only collect the data needed to perform our services and where we can identify a clear purpose for collecting the personal data in question.
Our purpose for collecting data when you interact with us as a candidate usually relates to our assignment towards our clients to identify and assess the best possible candidate for a certain position. Our purpose for collecting data about you in your role as client usually relate to our ambition to be able to interact with you smoothly and have sufficient information about you and your organisation to serve you in the best possible way. Finally, when you interact with us as other stakeholder, our purpose usually is aimed at collecting sufficient data about you and your organisation so we can interact with you in a smooth and professional fashion.
In addition, we may also process other Data relevant to a search process or leadership services assignment to provide us with a better understanding of you as a person and as a potential employee to one of our clients. Information relevant to a search process or leadership services assignment may differ on a case-by-case basis depending on the relevant position to be filled and varying instructions from our clients from time to time.
The information may, to the extent necessary, however include:
information about you; such as your academic degree(s), employment history and board positions, information in applications, interviews, psychological evaluations, test results and assessments of you;
information about your personal situation; such as civil status and relevant information about your personal life e.g. previous convictions; and
financial information about you such as information about your current income and debts or potential payment defaults.
The detailed purposes for the managing of your Data are outlined below. Needless to say, our ambition is to handle your Data with integrity and we strive to only process Data which is necessary and relevant.
THE WAY WE COLLECT YOUR PERSONAL DATA
From You Directly
This kind of information might be provided by you by different means of communication, e.g. over www.closethegap.nu, by submitting us written material, or when being in direct contact with us or through your interactions with our various partners from time to time.
This collection also occurs when you communicate with us by e-mail, phone, regular mail or any other form of communication such as social media ( e.g. LinkedIn).
From Third Parties
As a way of operating and run our services as a leadership services firm, we might also collect Personal Data available on the internet, e.g. social media (such as LinkedIn), from sources and through contacts with other individuals such as references provided by you.
We may also manage your Personal Data when we collect such Data from private or public registers e.g. from authorities and schools.
Should you be informed that we have gathered your Personal Data from a third party, please feel free to contact CloseTheGap’s Data Protection Officer. We are open to remove your information upon your request and/or answer any other questions relating to your Personal Data.
IF YOU DO NOT CONSENT TO US MANAGING YOUR PERSONAL DATA
As outlined above, we require certain types of Personal Data at CloseTheGap to run our Services. As an individual, you are by law entitled to refuse the submission of any Data to us should we be in contact with you directly. You are also free to notify us at any time that you do not wish to participate in any collection or other processes with us where your Personal Data may be registered.
USE OF YOUR PERSONAL DATA
Our ambition is to only collect Personal Data which is relevant and needed for the reason it is collected. At CloseTheGap, we merely manage your Personal Data for the specific and limited purposes as listed below:
to create an overview of markets and individuals for our clients’ and our own needs;
to handle position applications and/or to run specific search assignments and leadership consultancy assignments on behalf of our clients;
to assess candidates through e.g. management audits;
to maintain and further develop our database with candidates for future client
to provide our Services and be an advisor to our clients;
for statistical reasons; and
for internal purposes in order to improve our Services.
TRANSFER OF YOUR PERSONAL DATA
Some Personal Data may be transferred or co-ordinated inside the European Union, to our affiliates, our service providers and other partners, authorities, e.g. within the computer network of affiliated companies to CloseTheGap, to fulfil the purposes above as well as in order to fulfil obligations according to law or contracts. Subsequently, we may also share your Personal Data with our clients should you e.g. be deemed as a suitable candidate in an assignment.
When relevant in order to ensure that Personal Data entrusted to us will not be abused, we require third parties to ensure adequate precautions are in place to protect the Data and that applicable laws are complied with.
YOUR CONSENT TO OUR PROCESSING OF YOUR PERSONAL DATA
By providing us with your Personal Data, you consent to the managing of your Data, including any sensitive data and personal identification number (when certain identification is necessary), and to the collection of Personal Data from third parties, as set out in this Policy.
In addition to a general consent of our processing of your Data, you hereby expressly approve our processing of your current personal situation and financial situation as specified above under the section ”Introduction to this Policy”.
You also expressly consent to the transfer of your Data to our affiliates at any time, our service providers and partners inside the European Union.
You may withdraw your consent at any time. In such a case, we are obliged to inform you that we may not be able to provide our Services to you.
We will keep your Personal Data only for as long as reasonably necessary for purposes for which it was collected or for us to comply with legal and/or regulatory requirements.
YOUR RIGHT TO ACCESS YOUR PERSONAL DATA
We will provide you with the Personal Data we keep about you, upon the active request from you. You are also entitled to receive information of where this Data has been collected, the purpose of the processing and to which recipients or categories of recipients the information is disclosed. In addition, we will change or delete or supplement any Data that you inform us is inaccurate or in any other form incomplete.
If you wish to receive access to your Personal Data held by us, please contact our Data Protection Officer: email@example.com, mobile +46 79 007 07 07.
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CHANGES TO THE POLICY
At CloseTheGap, we strive to always improve the way we interact with our stakeholders. We therefore encourage you to reach out to anyone of us with feedback on how we could further improve the way we handle and manage your Personal Data.
Last updated: 29th October 2018