Dated May 24, 2018
(I) Who We Are and What this Policy Is
Welcome to Kilpatrick Group S.A, Lugano, Switzerland (“Kilpatrick,” “we,” “us” and “our” etc.) and its global website (http://www.kilpatrick.one ).
We are a boutique executive search firm and advisor to many respected organizations. We provide a variety of services to these clients and other parties, including, but not limited to: (1) executive search (we recruit executives for organizations); (2) board consulting (we conduct board effectiveness reviews and appraisals of directors, and assist in board successions); (3) leadership strategy services; (4) diversity and inclusion services and (5) CEO succession (collectively, and among others, our “Services”).
For additional information on our Services please visit our website www.kilpatrick.one
Our consultants provide these Services globally from our offices in 17 countries.
Kilpatrick is responsible for the processing of your personal data and information on its website.
In addition to terms defined elsewhere in this Policy, the following terms shall have the following meaning throughout this Policy:
“Personal Information” means any information that either (a) personally identifies a natural person; or (b) pertains to an identifiable natural person, i.e. someone who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity, or (c) constitutes individually identifiable information about an individual consumer collected by us online through our website and that we maintain in an accessible form, or that (d) we are otherwise required to protect under applicable data privacy laws (including, but not limited to, national, international and supranational data protection and privacy laws, directives, regulations and comparable legal acts). Examples of Personal Information include your contact details such as your name, email address, birthday or phone number as well as information about your professional education and experience, skills, preferences, membership in professional organizations, etc.;
“Processing” (and variations such as “Process”) means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, restriction, erasure or destruction;
“Sensitive Personal Information” means Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the Processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation;
(III) Processing of Your Personal Information
Depending on your interaction with the Site, your Personal Information is Processed as follows:
The Talent Gate – Declaration of Consent
As part of our Services, we specialize in the global search, placement and integration of candidates for executive and similar management positions (each a “Candidate”) on behalf of our clients (“Client Services”).
In the event you are interested in becoming a Candidate, you can share your resume through “LinkedIn” or register with “Not Actively Looking“. All information on your personal and professional background (“Candidate Information”) will then be accessible for Kilpatrick, and subject to our sole discretion, taking into consideration as part of the Client Services.
To do so, please visit https://www.kilpatrick.one/your-career and choose your preferred method to share your information.
Providing any Candidate Information is purely voluntary on your part. Although it is generally true that, the more information you share, the better we are able to assess your potential suitability for an open executive or similar management position, we urge you not to disclose any Candidate Information that is likely of little or no relevance or may not even be legally considered as part of common hiring processes. This applies, in particular, to Sensitive Personal Information.
If and to the extent you share Candidate Information with us by sharing your “LinkedIn“ profile or register with “Not Actively Looking“, we might follow up with you using the contact details you may have provided in order to clarify any questions we might have or obtain complementary information from you.
In addition, we might conduct assessments of your professional profile and perform searches for information on your personal and professional life publicly available via social media services (e.g. Facebook, Google, LinkedIn, Twitter, etc.), on the Internet or within data you have previously disclosed to us, provided that such information might be of importance to your qualification for a particular executive or similar management position. Any resulting information will be considered Candidate Information and be Processed as described below together with the Candidate Information you initially provided through the Site.
Your Candidate Information will be Processed by and on behalf of Kilpatrick. However, depending on how and where the Client Services need to be performed in your individual case, your Candidate Information might, in addition, be Processed by and on behalf of other Kilpatrick offices in countries throughout the world.
Your Candidate Information Processed by Kilpatrick might contain (a) your contact details (name, address, phone number, email address, etc.), (b) your biographical data, (c) information on your professional education, and (d) your educational credentials, professional diplomas and certificates. In addition, it may contain (e) your employment and compensation history, (f) data on your suitability for client opportunities we compile as part of our assessments of your professional profile, (g) information on your personal and professional life publicly available via social media services (e.g. Facebook, Google, LinkedIn, Twitter, etc.) or otherwise on the Internet that might be of importance to your qualification for a particular executive or similar management position, and (h) any Sensitive Personal Information you might choose to disclose to us.
Your Candidate Information will be shared with third parties as follows:
- Your Candidate Information will exclusively be stored by “LinkedIn“ or “Not Actively Looking“. The servers hosting the databases are operated by and accessible to third-party service providers acting on their behalf and as per their instruction in order to operate the servers.
- Via the databases, your Candidate Information will be available to the consultants and administrative staff of Kilpatrick offices for the purposes of providing the Client Services;
- Subject to our discretion, we might disclose excerpts of your Candidate Information such as your professional education and employment history with particular clients in order to confirm whether they might be interested in you as a Candidate with respect to an opening for an executive or similar management position they have informed us of. The information disclosed will be limited to what is necessary for this purpose. We will not disclose the entirety of your Candidate Information or otherwise introduce you to any client in detail without first obtaining separate and specific consent from you.
As part of our Client Services, your Candidate Information may be Processed for the purposes of executing searches for potential Candidates on behalf of clients that have an opening for an executive or similar management position, assessing your suitability for client opportunities, informing you of open executive or similar management positions potentially suitable for you, introducing you to clients as a Candidate and potential future member of their management, and or verifying your educational credentials, professional diplomas and certificates.
At no point will your Candidate Information be matched, linked or otherwise connected with Personal Information collected through other components of the Site for purposes other than providing Client Services. Your Candidate Data will be Processed until you revoke your declaration of consent given to “LinkedIn“ or “ Not Actively Looking “ . Upon the revocation of your declaration of consent, they will delete your Candidate Data and your data will no longer be accessible for Kilpatrick.
By sharing your Candidate Information with us through “LinkedIn“ or “Not Actively Looking“ , you explicitly consent to the Processing of your Candidate Information, including any Sensitive Personal Information you might choose to disclose, as described above. This includes, without limitation, the transfer of your Candidate Information, or parts thereof, to countries not providing an adequate level of protection of personal data. You acknowledge that you are under no obligation to provide your consent and that, if you choose to do so nonetheless, you may revoke your declaration of consent at any time with future effect by using the following contact details: email@example.com.
(V) Data Security
Protecting your Personal Information is important to us. We use appropriate technical and organizational measures and safeguards designed to help prevent unauthorized access, unlawful Processing, and unauthorized or accidental loss of your Personal Information. This includes, for example, the encryption of your communication with us over the Site based on the Secure Socket Layer (SSL) protocol.
(VI) Your Right to Information
Subject to the applicable law, you have the right to (a) obtain information about your Personal Information we Process, and to (b) request the correction, deletion or blocking of incorrect Personal Information or Personal Information not Processed in line with the applicable legal requirements. To make a respective request, please use the contact details provided in “How to Contact Us” below.
(VII) Amendments to This Policy
From time to time we may change our business activities and/or our policies and procedures with respect to the Processing of Personal Information. Where appropriate in these cases, we will, subject to applicable law, revise, supplement, or replace this Policy. When the Policy changes, we will post the substitute version and change the effective date listed at the beginning of the Policy.
When required by applicable law, however, we may provide you with advance notice of any changes to this Policy and with an opportunity to object to such changes. If you exercise your right to object, the changes will not become effective with respect to your Personal Information, but your ability to use our Services may be terminated or impaired. We will explicitly notify you of the consequences of the objection or non-objection to the extent and in the manner required by law.
(VIII) How to Contact Us
We encourage your questions and comments about this Policy and our privacy practices. Please contact us using the information below, and we will respond to you as soon as reasonably possible:
Kilpatrick Group S.A
Piazzetta San Carlo, 2
6900 Lugano ( CH)