Privacy Policy

WEBSITE PRIVACY POLICY

 

[Last updated March 2023]

 

Who are we?

We are Firefly Partners (a trading name of Topikimoro Ltd). We are a niche consultancy, working predominantly with private equity investors, providing a range of services including executive search, management due diligence and origination support. We also carry out executive coaching and other assessment services.

 

What does this Policy cover?

This Privacy Policy explains our use of personal data processed through the website, if you choose to contact us and our use of business contact details. It also explains how we use candidate personal data and the personal data of our clients.

 

What personal data do we collect and why do we use it?

The table below explains who we collect personal data about, what that personal data is and the purpose we process it for.

 

The last column sets out the ‘lawful basis’ we rely on for processing that personal data which is a requirement of data protection rules. Essentially, companies may only process personal data if they can identify a lawful basis from a list set out in the legislation.

 

Individual

Personal Data

Source and Purpose

Lawful Basis for Processing

Candidates

CVs, identification documents, educational records, work history, employment record and references, correspondence and other personal data provided by you as part of the recruitment or engagement process.

 

We rarely process special category information such as racial, disability, trade union or health information where you have made this available to us.

We mainly collect this information directly from you during the recruitment, engagement and onboarding stages.

 

Sometimes we collect information from third parties such as an agent acting on your behalf, such as an interim manager’s limited company, or from a third-party recommendation or a person giving a reference.

 

We do use some publicly available sources to find information about potential candidates, specifically LinkedIn, Google and company websites.

 

We may also use this information anonymously or in aggregate to compile industry, marketing and employment statistics.

The processing is necessary for our legitimate interests of assessing suitability for potential roles, to find potential candidates.

 

If you choose to give us special category data (listed in the second column), we obtain your express consent to process that.

Assessment participants

Contact details, correspondence, assessment information provided, analysis and recommendations and opinions.

 

Special category information such as health, disability or ethnicity or racial information is only processed if provided by you.

We collect most information directly from you during the assessment process.

 

Sometimes we collect information from third parties such as your employer, our client, or a person giving a reference.

 

We use some publicly available sources to find information about assessment subjects, specifically LinkedIn and company websites.

 

We use the information to perform assessment services commissioned by your prospective employer, your employer or an investor that is in process of evaluating your employer’s company.

Our legitimate interests as a business in providing management assessment services.

 

We only process special category data with your express consent.

Coaching clients (i.e. where you are a client of ours we are providing coaching services to)

Contact details, correspondence, assessments, information provided, analysis and recommendations and opinions.

 

Special category information such as health, disability or ethnicity or racial information is only processed if provided by you.

This information is given to us by you or your employer.

 

Occasionally we undertake feedback sessions as part of coaching which may involve the provision of information about you from other people known to or nominated by you.

 

We use the information to provide our coaching services to you.

Our legitimate interests as a business in providing coaching services. Some information may also be necessary specifically for us to perform the contract.

 

We only process special category data with your express consent.

References/

referees

Contact details and correspondence.

Reference contact details may be given to us by candidates as part of a recruitment process.

 

Other personal data about referees is given to us by you directly.

Our legitimate interests as a business in obtaining references on candidates.

Individuals who contact us with general queries

 

Contact details provided and correspondence.

This information is given to us by you.

It is used to respond to the query and keep a record of it.

Our legitimate interests as a business in responding to and keeping a record of correspondence.

Clients and potential clients

Contact details provided and correspondence. Contracts.

This information is given to us by you or from publicly available information (for example on your website).

 

It is used for us to fulfil contracts and engage in business discussions.

Our legitimate interests as a business in responding to and keeping a record of correspondence. Some information is also necessary for us to perform our contract – for example certain contact details.

Suppliers and contractors

Contact details and provided correspondence.

This information is given to us by you or from publicly available information (for example on your website).

 

It is used for us to fulfil contracts and engage in business discussions.

Our legitimate interests as a business in responding to and keeping a record of correspondence. Some information is also necessary for us to perform our contract – for example certain contact details.

Website visitors

Information from cookies. For more details see our Cookie Notice.

This information is collected via the cookies when you use our website.

Analytics data is used to produce reports to help us improve the services and information we provide to website visitors.

We only install non-essential cookies with your consent. For more details see our Cookie Notice.

 

Where we have indicated in the table above that we rely on legitimate interests for processing of personal data, we carry out a ‘balancing’ test to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to and can find out more about the information in these balancing tests by contacting us using the details below.

 

How long do we keep your personal data for?

We keep your information only for as long as is necessary for the relevant purpose. For example, if we have a contract with you, this will be for 7 years after expiry in order to assist us with any contractual claims. We use a number of criteria for determining the retention period including obligations under law, our need to defend or bring contractual claims within the statutory limitation period and consideration of the original purpose we collected it for.

 

Who do we share your personal data with?

Data may be shared in the following circumstances:

  • Where you are a candidate:
  • we share your personal data with the client who has a position to fill in order to determine with the client whether you are a good fit for an available position. Our clients are predominantly private equity investors;
  • we may share summary biographical information with a client in the early stages of an executive search, for example to identify or illustrate a typical profile within the search parameters.
  • where required for a specific role, we may conduct checks in order to verify information you have provided and where we do this we share your information with a background checks agency in the UK.

 

  • Where you are participating in an assessment process:
    • we share feedback and assessment reports that include information about you with the employer and/or investor commissioning the assessment process.

 

  • With professional advisors;

 

  • In the event of a sale of the company or its assets;

 

  • With suppliers but only subject to robust contractual protections;

 

  • Other companies in our group.

 

What happens if you do not provide us with the information we request or ask that we stop processing your information?

If you do not provide the personal data necessary, we may not be able to respond to your query or consider your application or request or to provide the relevant services to you.

 

Do we make automated decisions concerning you?

Automated decisions are those made without human intervention that have a legal effect on you or other similarly significant effect (for example determining whether you are eligible for a job). We do not carry out this type of processing activity.

 

We may carry out personality profiling on candidates with the candidate’s consent.

 

 

 

Do we transfer your data outside the UK and Europe?

We may sometimes transfer your personal data to countries outside the UK and European Economic Area, for example, if we are either using a supplier or working with a client based elsewhere. You can find the list of European member states by clicking on the following link: https://europa.eu/european-union/about-eu/countries/member-countries_en. The privacy laws in countries outside the UK and European Economic Area may be different from those in your home country.

 

Where we transfer data to a country that has not been deemed to provide adequate data protection standards, we always have security measures and approved model clauses or other adequate safeguards in place to protect your personal data. Please contact us if you would like more details about our safeguards for data transfers.

 

What rights do you have in relation to the data we hold on you?

By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country. In the UK this is the Information Commissioner.

 

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

  • baseless or excessive/repeated requests, or
  • further copies of the same information.

 

Alternatively, we may be entitled to refuse to act on the request in some circumstances.

 

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

 

Rights

What does this mean?

1.             The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Policy. If you have any additional questions, for example regarding transfers and locations of data or our legitimate interests basis, do please get in touch.

2.             The right of access

You have the right to obtain access to your information (if we are processing it), and certain other information (similar to that provided in this Privacy Policy).

This is so you’re aware and can check that we’re using your information in accordance with data protection law.

3.             The right to rectification

You are entitled to have your information corrected if its inaccurate or incomplete.

4.             The right to erasure

This is also known as the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right, there are exceptions.

5.             The right to restrict processing

You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

6.             The right to data portability

You have rights to obtain and reuse your personal data for your own purposes across different services. This is not a normal scenario for companies of our nature but if you have any questions you can contact us.

7.             The right to object to processing

You have the right to object to certain types of processing, including processing for direct marketing or where we are relying on our legitimate interests for processing (e.g. if you no longer want to be contacted with potential role opportunities).

8.             The right to lodge a complaint

You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.

9.             The right to withdraw consent

 

If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

 

Updating this Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in personal data protection legislation and best practices. When we make changes to this Privacy Policy, we will change the “last updated” date above and will notify you of any significant changes to this Privacy Policy.

 

How can you contact us?

If you are unhappy with how we’ve handled your information or have further questions on the processing of your personal data, please contact us here: Rona Posselt, rona@fireflypartners.co.uk.