About Carmichael Fisher
Carmichael Fisher (‘we’ or ‘us’ or ‘our’) is a global executive search firm headquartered in London, United Kingdom with offices in Amsterdam, Brussels, Boston, Frankfurt, Hamburg, London, Los Angeles, Paris, Philadelphia, Stockholm and Zurich.
Our registered office in the United Kingdom is at One Aldermanbury Square, London EC2V 7HR and we are a company registered in England and Wales under company number 05866930. For our operations conducted outside of the European Union, our representative within the European Economic Area (EEA), for the purposes of data protection, is this UK entity.
We are registered on the Register held by the Information Commissioner’s Officer (also known as the ICO, which is the the Data Protection Supervisory Authority in the UK).
We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Our services are uniquely aimed at adults and we do not knowingly process personal data or information related to children.
“You” are an existing candidate, potential candidate, client contact, consultant/contractor, referee, source or vendor involved in the introduction and/or supply of our executive search.
“Candidate” means an individual (applicant, prospect, existing) who is considered, evaluated or assessed by Carmichael Fisher to fill a temporary or permanent role with a Client.
“Client” means a hiring organisation looking to recruit temporary or permanent executives to whom we provide our executive search service to.
“Client Contact” means an individual who is an employee and responsible owner of the Client.
“Employee” means an individual who holds a position (whether paid or unpaid) of employment at Carmichael Fisher
“Referee” means an individual who provides employment reference for a Candidate
“Source” means an individual who helps us identify and provide market intelligence about a potential Candidate.
“Vendor” means any entity other than Carmichael Fisher that provides products or executive search to Carmichael Fisher to a contract with Carmichael Fisher.
Information We Collect
Candidate Personal Data
Our main purpose for collecting personal data from you (Candidate) is to provide you with Executive search services to recruit you into an executive position specified by a Client.
We have set out a table at the Schedule below which sets out the information collected by us or from third parties.
Information You provide to us: You provide information to us when you speak with a Carmichael Fisher Employee, email your curriculum vitae (CV), apply for an advertised role on LinkedIn or communicate with us in any way relating to the Executive search we provide.
You are not obligated to provide Carmichael Fisher with any personal information or participate in our executive search. Therefore, when we collect personal information directly from you, we consider this to be voluntary. If you are unwilling to provide us with certain requested information, please be aware this may limit our ability to consider you regarding the executive search service we provide.
The information we may collect from Candidates typically includes:
- Contact details such as your name, email address and phone number.
- Curriculum Vitae (CV) information such as your contact details, employment history (including job titles, salary and working hours), educational history, professional qualifications, languages, skill and personal activities.
- Identification data such as passport information to book your travel (when attending and interview with a Client) which includes your racial or ethnic origin and sex.
- Financial information such as bank account details to reimburse expenses incurred in relation to our Executive search (travel, accommodation and/or meal costs when attending an interview with a Client). We may collect financial information to document the expense and reimburse you.
- Other information such as immigration status, right to work documentation, and any other relevant information you may choose to share with us.
- A record of your marketing preference and our contact history with you is also recorded.
- Depending on the nature of the role, you may also provide us with information regarding your criminal record history.
Information we collect from third party sources about Candidates: We may collect personal information about you from publicly available sources, and third parties, such as previous employers, your school, university or college, professional regulators or government bodies based on information that has been provided by the candidates themselves, including under the following condition: (i) Sources may disclose personal information about you; (ii) our Clients may share personal information about you; (iii) we may obtain information about you from publicly available third-party sources (e.g., LinkedIn, news reports, press releases); and (iv) we may source personal information about you from third party data providers (e.g., GatedTalent) (v) and Referees may provide your information for reference checks. When we obtain information about you, from vendors or third-party providers, we ensure they are legally permitted or required to disclose such information to us. Further information is set out in the Schedule below.
Client and Client Contact Data
Our main purpose for collecting personal data from you (Client, Client Contact) is either with a view to entering into a contract with you or to fulfil our contractual obligation to you while we support you in recruiting executives via a retained search.
Information Clients provide to us: We require your contact details (such as name, telephone number, email address and job title) to ensure our relationship is efficiently managed. Collecting information about you is essential to our service and we may collect information when you contact us with a view of providing a service, email us with an interest to work with us, provide us with your business card or other information given to our employees at sales and marketing events, post information on websites or social media websites and sign a contractual agreement with us.
The information we may collect from Client contact typically includes:
- Contact details: such as your name, email address and phone number.
- Company information: such as postal address, details of your role, title and responsibilities within the company.
We also collect any feedback or opinion you share with us regarding a Candidate, queries you raise regarding our service and details of resourcing and recruitment requirements you share with us.
Information we collect from third party sources about Clients: We may seek more information about you or your colleagues by way of due diligence or other market intelligence including (i) from third-party market research and by analysing online and offline media; (ii) from attendee lists at relevant events, networking and conferences; (iii) from other limited sources and third parties. This may include from professional social media sites where such information is in the public domain, from any professional marketing materials or other publications (including your company’s website) which have been issued and maintained by your company or from your company itself, where we have initially been dealing with another department or another group entity.
Lawful basis for processing your personal data
Our principal lawful basis for processing your personal data is that it is in our legitimate interests to do, to be able conduct our executive search operations.
Where this is the case, we have carried out a thorough Data Protection Impact Assessment (DPIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate. We use the legitimate interests’ lawful basis for processing our data related to our core recruitment activities.
For example, when a Candidate has made their CV or details available to us for the express reason of potential employers being able to access this data, we consider that our legitimate interests as an Executive Search Agency and those of our Clients are likely to align with the interests of that Candidate. Clearly, it is in the interests of all parties to find the Candidate a suitable role, and as such, these interests do not outweigh the Candidate’s privacy rights.
In respect of a Candidate’s social media or LinkedIn account, we also agree with ICO Guidance, which states that when a Candidate has selected an “Available for Work” or “Please Notify Recruiters” option, the Candidate would expect those who view their profile to use their details for recruitment purposes. Again, our legitimate interests are likely to align with the interests of the Candidate in their search for a job.
If a Candidate has not selected the “Available for Work” option then we will never assume the Candidate expects to be contacted for work, and we therefore consider that the interests of such potential Candidates in maintaining control over their data overrides any of our legitimate interests as an Executive Search Agency (or those of our Clients). In this instance, we would always seek the individual’s consent and ensure that they confirm they are happy to collaborate with us before any information is taken from their profile.
In any case, any contact we make with Candidates via social media, this is always carried out in compliance with the GDPR and other legal requirements (such as the “PECR“) which govern how we can contact you by electronic means or by using new technologies.
Other Lawful Bases:
|Data Subject||Lawful basis for processing your information in accordance with Article 6||Processing Activity|
|Legitimate interest||Research project and Talent mapping|
|Consent and Legal obligation||Booking international travel as required for a Client interview|
|Client Contact||Consent||Direct Marketing|
|Contractual obligation||Retained executive search|
|Legitimate interest||Business Development|
|Referee||Legitimate interest||Reference check|
|Source||Legitimate interest||Information gathering|
|Vendor||Legitimate interest and Contractual obligation||Assessment and one-off projects|
How we use your personal data
Candidate Personal Data
Executive Search: We use your data to provide our executive search service to our Clients. This includes conducting research projects to assess the market for suitable Candidates, engaging with Candidate to complete our manual screening process, interviewing over the phone or in person as part of our initial assessment against the Client brief, shortlisting Candidates as specified by our Client, supporting Clients with the final appointment process and maintaining contact with appointed Candidates.
Marketing Activities: We may use your data to send you direct marketing information which we have identified as beneficial to you based on your consent. If you object to receiving our marketing information, we ensure you can actively opt-out by explicitly providing you with our consent notice. In all cases, we ensure any marketing activities comply with the GDPR and other legal requirements (such as the Privacy and Electronic Communications (EC Directive) Regulations 2003 also known as “PECR“) which govern how we can contact you by electronic means or by using new technologies.
In respect of our Candidates, we have provided a table at the Schedule below which sets out how we use your information in order to provide you with the highest quality recruitment services.
Client and Client Contact Data
Executive Search: We use your data to provide our executive search service to you. This includes engaging with you to confirm our contractual obligation as identified in the retained executive search terms and conditions, contacting you to feedback on research projects via candidate reports, telephone calls and face to face meetings, shortlisting Candidates with you as specified in the brief you provide and supporting you with the final appointment process.
Business Development: We may use your data to send you direct marketing information for business development and with the view to perform a contract with you. If you object to receiving our business development information, we ensure you can actively opt-out by explicitly providing you with our consent notice.
Marketing Activities: We may use your data to send you direct marketing information which we have identified as beneficial to you based on your consent or in relation to services that you have requested from us. If you object to receiving our marketing information, we ensure you can actively opt-out by explicitly providing you with our consent notice. In all cases, we ensure any marketing activities comply with the GDPR and other legal requirements (such as the “PECR“) which govern how we can contact you by electronic means or by using new technologies.