REFEREE DATA PRIVACY POLICY

Purpose

As part of any search process, Albany collects and processes personal data relating to individuals who provide personal and employment references for candidates that it represents. Albany is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does Albany collect?

Albany may collect a range of information about you in the course of obtaining a personal or employment reference for a candidate from you. This may include:

  • your name and contact details, including email address and telephone number;
  • details of your employment history (including job titles and work history);
  • information about your personal connection to, and relationship with, a candidate; and
  • information about your experience of working with a candidate and your views and opinions in relation to a candidate’s skills, qualifications, aptitude, experience, performance, disciplinary and attendance record and other personal attributes in the context of their work.

 

Albany may collect this information from you via conversations or other forms of communication. Albany will also collect limited personal data about you from candidates, for example, your name and contact details.

Data will be stored in a range of different places, including in our case management systems and on other IT systems (including email).

Why does Albany process personal data?

Albany needs to process personal data to take steps to obtain personal and employment references in relation to candidates to progress their interest in roles.

Albany, its candidates and its clients have legitimate interests in processing personal data provided by personal and employment referees during the search process and for keeping records of such references. Processing personal data from referees allows Albany and its clients to assess candidates’ suitability for roles, progress candidates’ interest in roles and ultimately place candidates into roles. Albany may also need to process data provided by referees to respond to and defend against legal claims.

Where Albany relies on legitimate interests as a reason for processing data provided by referees, it has considered whether or not those interests are overridden by the rights and freedoms of referees and has concluded that they are not.

Albany will not use your data for any purpose other than progressing a candidate’s interest in a role unless we have your consent to do so.

Who has access to data?

Your information will be shared internally within Albany and with our partner organisations Forme Partners and Altima, for the purposes of search processes.

Albany will share your data with third parties in limited circumstances and only after notifying you that we will do so. For example, Albany will share your data with the relevant client in order to progress the search process and enable us and our client to assess the suitability of the candidate for a role. Albany will not share your data with the relevant candidate unless required to do so in order to comply with a legal obligation.

Your data may be transferred to countries outside the European Economic Area (EEA) when it is stored in our cloud based IT and case management systems. Data is transferred outside the EEA in accordance with the conditions set out in the GDPR and only to countries that have been certified by the European Commission as having an adequate level of data protection in place. For example, where our cloud service providers hold your data on servers in the United States, they are certified under the EU-U.S. Privacy Shield Framework.

How does the organisation protect data?

Albany takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

For how long does Albany keep data?

Subject to the rights set out below, Albany will hold personal data relating to referees for the duration of the search process and for an indefinite period of time after the search process in order that we can provide ongoing support to candidates by assessing their suitability for any future roles and bringing potentially suitable roles to their attention.

Your rights

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your data on request;
  • require Albany to change incorrect or incomplete data;
  • require Albany to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
  • object to the processing of your data where Albany is relying on its legitimate interests as the legal ground for processing; and
  • ask Albany to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override Albany’s legitimate grounds for processing data.

 

If you would like to exercise any of these rights, please contact James Goodrich, Managing Partner on 07753438010 or by email at jgoodrich@albanypartners.co.uk

If you believe that Albany has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Albany. However, if you do not provide the information, Albany may not be able to progress a candidate’s interest in a role properly or at all.

Automated decision-making

Albany does not operate search processes based solely on automated decision-making.