Privacy And Cookies Policy
Introduction
ICC Executive Search BV, hereafter “ICC”, established in The Netherlands, is committed to protecting the privacy of your personal data. This statement summarizes our policy regarding the collection, use and transfer of your personal data, the security measures ICC employs to protect such data and your rights in relation to it.
Gathering information
Our clients expect that we identify the best individuals to fill roles within their organisations. So, we need to research systems, online databases and other information sources, and talk to many individuals. Besides our clients, these will include referees and sources to help inform our decision-making process.For certain roles, we may run an advertisement to which you may respond, either electronically or via mail. Other roles may involve one of our researchers or consultants calling you to discuss the details. Then, we will either inform you verbally that we will process your personal data or send you a Data Privacy Notice. Both will direct you to this Privacy Policy.
Besides filling particular leadership vacancies, we also process personal data when we conduct market intelligence exercises to map out particular business sectors or functions to help clients understand the available talent.The nature of our work means we are required to process personal data quickly, confidentially and often without reference to the data subject. Accordingly, we process such data in accordance with the Data Protection Laws, regularly using our legitimate interest where it is not possible or feasible to speak directly with the data subject. Beyond this, we will seek consent in the circumstances explained later in this policy document.We collect information from candidates directly when you send your CV or resume to us digitally. We also collect information from you when you speak with an employee of ICC.
Besides filling particular leadership vacancies, we also process personal data when we conduct market intelligence exercises to map out particular business sectors or functions to help clients understand the available talent.The nature of our work means we are required to process personal data quickly, confidentially and often without reference to the data subject. Accordingly, we process such data in accordance with the Data Protection Laws, regularly using our legitimate interest where it is not possible or feasible to speak directly with the data subject. Beyond this, we will seek consent in the circumstances explained later in this policy document.We collect information from candidates directly when you send your CV or resume to us digitally. We also collect information from you when you speak with an employee of ICC.
How we use your personal data
We will not process your personal information in a way that is incompatible with what is outlined in this Privacy Policy and we will use our best efforts to ensure that data is accurate, complete, current and reliable for its intended use.
Candidate
We will not process your personal information in a way that is incompatible with what is outlined in this Privacy Policy and we will use our best efforts to ensure that data is accurate, complete, current and reliable for its intended use.
- Processing 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.
- The data is used in the usual course of our business to provide our services to clients. This may include assessing your suitability for executive and non-executive roles, presenting you as a prospective candidate to potential employers (ICC’s clients), contacting you for an assignment (executive search or assessment) or verifying the details of your profile.
- Searching for relevant candidates for confidential recruitment assignments where our client is not initially named. This means that if we believe you are suitable for a specific role, we may pass your basic details on to the relevant client. If that client agrees that you might be suitable, we will then discuss this with you in more detail. You might be interviewed for the role by one of our consultants. If successful, you might be shortlisted for interview by our client. At this point, we will pass further details to the client and you may receive further direct correspondence from them.
- Your personal information may also be shared with Referees or Sources in order to obtain additional information about you so we can provide a more accurate profile to our clients.
- From time to time, we conduct mapping or research exercises on behalf of our clients. This is to enable them to understand a particular market. Here, we may include certain aspects of your personal data. You will not be contacted by any third party about this unless we first obtain your consent.
- For the performance of a contract, we have concluded with you as an individual, most likely an assessment or coaching programme.
- For equality monitoring purposes, to understand the diversity of our applicant pool, but only if admissible under the applicable law. (This information is anonymised and aggregated).
- Improving the service we offer. For example, you may be asked to complete one of our online satisfaction surveys.
- For marketing purposes to send you information on our services, white papers, newsletters, events and so forth. Please note you may opt out from receipt of marketing materials at any time by writing to us.
- Finally, your information may also be shared with any competent law enforcement, regulatory or governmental body, or a court of law if necessary to exercise our legal rights, protect your interests or as required by applicable law.
We will only use your information in accordance with this Policy, or where we are required or authorised by law to disclose your information to others or, have your permission to do so.
Please be aware that we are not responsible for the data processing activities of others, such as our clients.
Client
We will use client data to perform our services to you and other legitimate business purposes such as marketing.
The data collected will be used in the context of the provision of our or your services. We may also use the data for other business purposes, including data analytics, benchmarking and statistic purposes. We may use the personal data collected to contact you in relation to any of our services that we believe may be of interest to you.
The data collected will be used in the context of the provision of our or your services. We may also use the data for other business purposes, including data analytics, benchmarking and statistic purposes. We may use the personal data collected to contact you in relation to any of our services that we believe may be of interest to you.
Source and Referee
We will use source and referee data to perform our services, in particular, to enable us to obtain your opinions on a candidate.
We will use the collected data to obtain information regarding your experience with, and thoughts and opinions on a particular or potential candidate.
If a candidate provides us with your details as a Referee, we may share your contact information with our clients to allow them to evaluate a candidate for a specific position. Any reference, opinion or feedback you provide to ICC as a Referee or Source shall in no case be attributed to you if shared with a client. We may also use your contact details to contact you in relation to any of our services that we believe may be of interest to you.
We may also use this information to enable us to market our services to you as a potential client. We may as well invite you to become a candidate in respect of the provision of our services.
We will use the collected data to obtain information regarding your experience with, and thoughts and opinions on a particular or potential candidate.
If a candidate provides us with your details as a Referee, we may share your contact information with our clients to allow them to evaluate a candidate for a specific position. Any reference, opinion or feedback you provide to ICC as a Referee or Source shall in no case be attributed to you if shared with a client. We may also use your contact details to contact you in relation to any of our services that we believe may be of interest to you.
We may also use this information to enable us to market our services to you as a potential client. We may as well invite you to become a candidate in respect of the provision of our services.
Intellectual Capital
We may contact you from time to time to share intellectual capital and thought leadership that we have published which we believe could be of interest to you or relevant to your role at your organization. You may opt out of receiving these communications at any time.
Convening
From time to time we may contact you with an invitation to attend an industry- or role-specific event, such as a dinner or charity event. You may opt out of receiving these invitations at any time.
Market Intelligence
We may retain and use personal information for research, benchmarking, and market norms in order to provide and develop our services and intellectual capital, and remain aligned with market standards.
The Information We Collect
ICC is an executive search firm which collects, uses and stores a variety of personal data necessary to provide such services.
Candidate
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, date of birth, education and career history and curriculum vitae (CV), or resume. Your CV or resume may contain employment history, education, professional qualifications, memberships, details of papers written, references and referees, among other things.
Based on your explicit consent, we will also process any relevant psychometric assessments, psychological tests, or results from such assessments or tests.
From time to time, we may ask you to provide information relating to protected characteristics, such as your race or marital status. We do this for equal opportunity monitoring purposes and from time to time online, but only if that’s admissible under local law. This information is always anonymised and aggregated and will not be revealed to third parties without your specific consent.
Additionally, as some of our clients may be subject to employment diversity requirements ICC may be required to share such information insofar as it pertains to the search you are a part of.
We might also collect personal data from third-party databases and other public sources.
Based on your explicit consent, we will also process any relevant psychometric assessments, psychological tests, or results from such assessments or tests.
From time to time, we may ask you to provide information relating to protected characteristics, such as your race or marital status. We do this for equal opportunity monitoring purposes and from time to time online, but only if that’s admissible under local law. This information is always anonymised and aggregated and will not be revealed to third parties without your specific consent.
Additionally, as some of our clients may be subject to employment diversity requirements ICC may be required to share such information insofar as it pertains to the search you are a part of.
We might also collect personal data from third-party databases and other public sources.
Assessment Data
If you are assessed as part of our services, we may collect information such as your name and email address, cultural-style background, qualifications, work experience, details regarding your employment, responsibilities at work, your professional views and opinions, as well as any other information and responses you may provide to evaluative measures, surveys and interviews (including where applicable interview recordings and transcripts of such recordings). Providing additional personal data such as age, gender, and ethnicity is voluntary and will not affect the assessment results.
Referee or Source Data
As well as basic contact information we will also collect information regarding your credentials as a source, details of your relationship/knowledge of a candidate and your opinions of that individual.
If you are an individual who provides a personal reference or feedback for a candidate (depending on the circumstances we may classify you as a Referee or Source), we may collect and process your contact details, certain professional details (such as title, occupation, qualifications and employment history) and your connection to the candidate. We may collect this information directly from you, the candidate or from publicly available sources. We will use this information to gather information on the relevant potential candidate such as your connection to, experience with, and opinion about such potential candidates. Any reference or feedback you provide about a candidate would not be attributed to you if shared with third-parties. We may also use your contact details to contact you in relation to any of our services that we believe may be of interest to you.
If you are an individual who provides a personal reference or feedback for a candidate (depending on the circumstances we may classify you as a Referee or Source), we may collect and process your contact details, certain professional details (such as title, occupation, qualifications and employment history) and your connection to the candidate. We may collect this information directly from you, the candidate or from publicly available sources. We will use this information to gather information on the relevant potential candidate such as your connection to, experience with, and opinion about such potential candidates. Any reference or feedback you provide about a candidate would not be attributed to you if shared with third-parties. We may also use your contact details to contact you in relation to any of our services that we believe may be of interest to you.
Client Data
As well as basic contact information we will also collect information about your role and other information provided to us by your organisation.
If you are an ICC client, we will collect and use information about your company and individuals within your company for the purposes of fulfilling our obligations to you and furthering our business relationship. Data collected will typically comprise your contact details (such as name, telephone number, email address, job title, and business record related to our services).
If you are an ICC client, we will collect and use information about your company and individuals within your company for the purposes of fulfilling our obligations to you and furthering our business relationship. Data collected will typically comprise your contact details (such as name, telephone number, email address, job title, and business record related to our services).
Sensitive data
From time to time, we will seek your consent to process personal data in respect of certain specific and limited purposes. We will always do this before processing any sensitive personal data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sex life and sexual orientation, genetic and/or biometric data. We encourage you not to provide us with sensitive personal data unless it is specifically requested, and we have your consent.
Legal basis for processing your personal information
ICC’s legal basis for collecting and using the personal information described in this policy will depend on the personal information and processing activity involved and the context in which it was obtained.
Executive Search
We will process basic personal information about you, such as your contact details (name, address, email, phone number) and information that would normally be included in a curriculum vitae (education history, employment history, professional experience, compensation history where permitted by local law, etc.), and competencies, as well as any additional information that may assist us in presenting the best individuals for the most appropriate roles (such as professional or relocation interests) on the basis of legitimate interest, or other legal grounds (such as consent) where required by applicable local legislation, provided the processing of such information is not overridden by your own privacy interests or your rights and freedoms as provided by law.
Once we proceed to the later stages of the search process, we will ask you to sign a consent form allowing us to process (and share with our clients and background check providers if relevant and necessary to the search process) any information required for background checks and/or employment diversity requirements, including any potentially sensitive information that may come to light during interviews as well as any insights that we may provide to our clients based on the foregoing.
If we are unable to obtain your consent at the relevant stage of the process, any information we process for employment diversity requirements shall be done on the basis of reasons of substantial public interest, or applicable laws and/or the requirements imposed by local authorities. However, we shall obtain your consent prior to sharing such information with our clients.
Once we proceed to the later stages of the search process, we will ask you to sign a consent form allowing us to process (and share with our clients and background check providers if relevant and necessary to the search process) any information required for background checks and/or employment diversity requirements, including any potentially sensitive information that may come to light during interviews as well as any insights that we may provide to our clients based on the foregoing.
If we are unable to obtain your consent at the relevant stage of the process, any information we process for employment diversity requirements shall be done on the basis of reasons of substantial public interest, or applicable laws and/or the requirements imposed by local authorities. However, we shall obtain your consent prior to sharing such information with our clients.
Assessment
For assessment we will process the information obtained as well as your contact information and details about your employment and background (as detailed above) on the basis of legitimate interest, or other legal grounds (such as consent) where required by applicable local legislation, in order to provide our services to our clients.
Interviews
In order to facilitate the interview processes for both our Executive Search and Assessment, we may request to record the interview session which will then be transcribed by a third party to ensure the information obtained is entirely accurate for our review. In the event of a planned recorded interview session, we will obtain your consent prior to recording.
If you require any further information concerning the legal basis on which we process your personal information, you may contact us at privacy@iccxs.com.
If you require any further information concerning the legal basis on which we process your personal information, you may contact us at privacy@iccxs.com.
Keeping information secure
To prevent unauthorized access, maintain accuracy of data and ensure the proper use of information, ICC has implemented appropriate legal, physical, technical and security procedures to protect the confidentiality of and safeguard the personal information collected, and prevent against accidental loss, unauthorized access, or unlawful processing. These measures will be reviewed over time and updated to remain aligned with legal and technological developments. 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.
Please be aware that we are not responsible for the data processing activities of others, such as our clients.
Please be aware that we are not responsible for the data processing activities of others, such as our clients.
Information about others
If you provide us with information about other individuals, like details of a referee or personal contact, you must ensure they’ve agreed to this. We would advise you to keep a record of their agreement and provide them with a copy of, or link to, this Privacy Policy.
Keeping your records
ICC will retain your personal data only for as long as the data is needed in connection with the purposes for which it is being collected and used. The following criteria will be used to guide us when retaining your information:
- We will retain personal data for as long as we maintain an active relationship with you;
- Once our relationship with you has ended, your personal data may still be relevant for our current or future legitimate business purposes, for example we may be required to retain certain personal information for our business records if you have been placed into a role by us, or for us to be able to establish, exercise or defend our legal rights;
- Certain data may be required to be stored in order to show we are compliant and have fulfilled our obligations towards our clients or to continue meeting any of our obligations once we have completed a client assignment in which you may have been involved.
Your Rights
You have the right to access, erase, correct, update or complete your personal data, or to request no further contact from ICC. Additionally, you have the right to request the transfer of your personal data to a third party, to object to the processing of your personal information, to ask us to restrict our processing of your personal information, or to withdraw your consent at any time. If you wish to exercise any of these rights you may contact privacy@iccxs.com.
Should you request that we remove your personal information from our database, please note that we may retain a minimal amount of personal information about you record your wish for your data to be removed, and to keep a record of the information disclosed to our clients. If deletion (or anonymization if applicable) of your personal data is not possible (for example because your personal information has been stored in backup archives) then we will securely store your personal information and isolate it from any further processing until deletion is possible.
If we have collected and processed your personal information on the basis of your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect any processing performed prior to your withdrawal nor will it affect processing on the basis of lawful processing grounds other than consent.
Should you request that we remove your personal information from our database, please note that we may retain a minimal amount of personal information about you record your wish for your data to be removed, and to keep a record of the information disclosed to our clients. If deletion (or anonymization if applicable) of your personal data is not possible (for example because your personal information has been stored in backup archives) then we will securely store your personal information and isolate it from any further processing until deletion is possible.
If we have collected and processed your personal information on the basis of your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect any processing performed prior to your withdrawal nor will it affect processing on the basis of lawful processing grounds other than consent.
Contact about Privacy Policy
If you have any questions about this Privacy Policy, or would like to exercise your rights with respect to your personal data, please contact us at privacy@iccxs.com.
If you have a complaint about how we have handled your personal data, contact us at privacy@iccxs.com, and we will investigate your complaint.
Finally, you have the right to bring a complaint to the relevant data protection authority in your jurisdiction about our collection and use of your personal information. For more information on how to lodge a complaint, please contact your local data protection authority.
If you have a complaint about how we have handled your personal data, contact us at privacy@iccxs.com, and we will investigate your complaint.
Finally, you have the right to bring a complaint to the relevant data protection authority in your jurisdiction about our collection and use of your personal information. For more information on how to lodge a complaint, please contact your local data protection authority.
Material Changes to the Privacy Policy
ICC reserves the right to modify or amend the Privacy Policy at any time and for any reason. If there are material changes to the Privacy Policy, we will post those changes here and take appropriate measures to keep you informed. Please check this Privacy Policy from time to time to stay informed.
If you have any questions about your personal information, please e-mail ICC at privacy@iccxs.com.
If you have any questions about your personal information, please e-mail ICC at privacy@iccxs.com.
Cookies & IP address Policy
ICC may use browser cookies on this website. Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website. We use cookies to provide a higher quality, more relevant, user experience by storing user preferences and monitoring user trends, as well as to deliver services requested by you.
By using our website you accept the use of cookies in accordance with this Cookie Policy.
If you do not accept the use of these cookies please disable them by following the instructions in http://www.allaboutcookies.org/manage-cookies/ or by changing your browser settings as indicated below so that cookies from this website cannot be placed on your computer or mobile device.
By using our website you accept the use of cookies in accordance with this Cookie Policy.
If you do not accept the use of these cookies please disable them by following the instructions in http://www.allaboutcookies.org/manage-cookies/ or by changing your browser settings as indicated below so that cookies from this website cannot be placed on your computer or mobile device.
Which cookies do we use?
We use customized and proprietary JavaScript code provided by third-party integrated platforms which may include, but are not limited to, Google Analytics, Hotjar, Google Tag Manager, Quantcast, Crazy Egg and Visual Website Optimizer to collect and transmit visitor information to their servers. When a user visits ICC’s website, this code contacts the respective third-party platforms’ servers and sends the aforementioned data. This data is stored, devoid of personally identifiable information, on the third-party server for the purposes of analysis that will be used to improve and provide contextual experiences to site visitors.
More information about the ways in which Google Analytics collect and process your personal data can be found here: www.google.com/policies/privacy/partners.
You can opt-out of Google Analytics here: tools.google.com/dlpage/gaoptout For further details about Hotjar, please see Hotjar’s privacy policy by clicking on this link. Please note that Hotjar does not store identifiable personal data but stores a pseudonymized user profile. Neither Hotjar nor us will ever use this information to identify individual users or to match it with further data on an individual user.
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link. (https://www.hotjar.com/legal/compliance/opt-out).
Necessary cookies – These cookies are essential for you to move around the website and use its features, such as accessing secure areas of the website. Use of cookies may also allow us to automate entry into password protected portions of the site, if applicable, so that you will not need to re-enter your password each time you visit our site.
Functionality cookies – These cookies allow the website to remember choices you make and provide enhanced, more personalized features. They may also be used to provide services in the way you have specified, such as collating data in a report.
Performance cookies – These cookies collect information about how you use our website, for instance which pages you visit and how often. These cookies do not collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve our website and the service we provide to you.
We may also perform IP lookups to determine your domain to more accurately gauge our users’ demographics. ICC may also monitors IP addresses for security purposes, trend analysis, website administration, user movement tracking and broad demographic information gathering for aggregate use. The IP address of the computer you use to access ICC’s website is not linked to any personal information you otherwise provide to us.
More information about the ways in which Google Analytics collect and process your personal data can be found here: www.google.com/policies/privacy/partners.
You can opt-out of Google Analytics here: tools.google.com/dlpage/gaoptout For further details about Hotjar, please see Hotjar’s privacy policy by clicking on this link. Please note that Hotjar does not store identifiable personal data but stores a pseudonymized user profile. Neither Hotjar nor us will ever use this information to identify individual users or to match it with further data on an individual user.
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link. (https://www.hotjar.com/legal/compliance/opt-out).
Necessary cookies – These cookies are essential for you to move around the website and use its features, such as accessing secure areas of the website. Use of cookies may also allow us to automate entry into password protected portions of the site, if applicable, so that you will not need to re-enter your password each time you visit our site.
Functionality cookies – These cookies allow the website to remember choices you make and provide enhanced, more personalized features. They may also be used to provide services in the way you have specified, such as collating data in a report.
Performance cookies – These cookies collect information about how you use our website, for instance which pages you visit and how often. These cookies do not collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve our website and the service we provide to you.
We may also perform IP lookups to determine your domain to more accurately gauge our users’ demographics. ICC may also monitors IP addresses for security purposes, trend analysis, website administration, user movement tracking and broad demographic information gathering for aggregate use. The IP address of the computer you use to access ICC’s website is not linked to any personal information you otherwise provide to us.
How to control cookies?
With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored on your computer. Please refer to your browser instructions (usually located within the “Help”, “Tools” or “Edit” facility) or a help screen to learn more about these functions and how to use them. Please be advised that certain sections or functionalities of the site may be inaccessible to you if your browser does not accept cookies.
For further information on cookies, including how to see which cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
For further information on cookies, including how to see which cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.