BACKGROUND:

The Frome Partnership understands that your privacy is important to you and that you care about how your personal data is used. We respect and value your personal data and we are committed to its protection.

1. What this Policy covers
The Frome Partnership is an Executive Search firm specialising in the Real Estate Sector globally. This notice explains how we collect, use, store and disclose information relating to our activities as a high level executive search firm (our Services).

2. The information we collect
If you are a candidate
As a potential candidate for an Executive Search assignment we may collect some or all of the following personal data:

• Name, contact details such as telephone numbers, e-mail and address details, education and qualifications, career history, interests and activities, diversity information, compensation details, language skills, nationality, photographs, particular skills and personal ambitions, and contact history. Also other information you chose to disclose to us, interview notes and other information deemed relevant for any potential employment opportunities.

Your personal data is obtained either directly from you or from third party sources such as Market Sources and Referees, News reports, other publically available sources and Professional/ authorised background check providers.

If you are a client or supplier

• We collect data in the course of the provision of our Services to you or in the provision of your services to us. This is typically limited to name, job title, contact details: work telephone / mobile and work email.

If you are a Referee

• We seek your thoughts and experience of a particular potential candidate in the course of providing our services to our clients. In addition we may use your details to contact you in relation to the provision of our services.

3. How do we use your personal data?
Under the GDPR, we must always have a lawful basis for using personal data. We use your personal data to respond to your enquiries, provide our Services as part of our Legitimate Interest as an Executive Search Consultancy business and to satisfy our legal rights and obligations.

We will process basic personal information, such as contact details and usual CV information such as career history, academic and educational qualifications on the basis of Legitimate Interest, provided the processing of such information is not overridden by your privacy interests or your rights or wishes.

If more detailed or sensitive information is required in order to proceed to further stages of the Executive Search process we will seek your explicit consent to enable us to share your information with a particular client for a specific assignment.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR including:

• Requiring an assurance scheme/framework for example, American Privacy Shield framework
• Requiring a privacy policy that is compatible with the GDPR
• Requiring a Data Processing Agreement if we are the controller of the data set

From time-to-time we may contact you to share thoughts and ideas that we think you may find of interest. This may include articles or news updates that we publish as well as potential business ideas. You may opt out of receiving these at any time.
Email: cbarber@tfp.eu.com

4. How long will we keep your personal data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected, or retain an active relationship with you. We may keep your data if it is still relevant for our current or future Legitimate Business Interests. Certain data may be kept to demonstrate that we have fulfilled our obligations towards our clients.

5. How and where do we store your personal data?
Your personal data is held on our Database, and IT systems. Some information may be held in hard copy format in our secure off-site location. We take reasonable and appropriate technical and security measures to protect your data from loss, misuse or unauthorised access or disclosure. This includes the following:
• Insuring all computer operating systems and applications are up-to-date
• Insuring all computers are protected with anti-virus security solutions
• Where necessary using encryption to protect the data
• Changing passwords frequently

6. How can I access my personal data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All Subject Access Requests should be made in writing and sent to the email or postal addresses shown in Part 9. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a Subject Access Request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will aim to respond to your Subject Access Request within 2 weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

7. Use of Cookies

We do not use cookies to collect personal data on you.

Our website uses cookies to better the user’s experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.

Cookies are small files saved to the user’s computer hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.

Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.

Our website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information http://www.google.com/privacy.html.

8. What are your rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 9.
b) The right to access the personal data we hold about you. Part 9 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 9 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 9 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 9.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

9. How do you contact us?
To contact us about anything to do with your personal data and data protection, including to make a subject access request or making an objection about the use of the data or who we share it with, please use the following details for the attention of Caroline Barber:
Email address: cbarber@tfp.eu.com
Telephone number: 02078989333
Postal Address: The Frome Partnership, 23 Berkeley Square, London, W1J 6HE

10. Information about us
The Frome Partnership
A Limited Company registered in England under company number 07933086
Registered address: 6th floor, 25 Farringdon St, London, EC4A 4AB
Main trading address: 23 Berkeley Square, London, W1J 6HE
Telephone Number: 0207 898 9333
VAT number: 131797404

11. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

If there are material changes to this Privacy Policy, we will post these changes here and take appropriate measures to keep you informed.