Short Version

Accenian takes the privacy of its customers very seriously. This privacy policy explains how we use any personal information that we collect about you, when you use this website www. Accenian.com and all associated Accenian micro-sites linked to this website (collectively “Our website”). We also comply fully with the Data Protection Act 2018 (the “Act”) and the General Data Protection Regulation (the “GDPR”).

For the purposes of the Act and the GDPR, the GDPR sponsor is Nick Harrington, 50 Mark Lane, London, EC3R 7QR in the United Kingdom. Accenian being a part of Eximius Group is registered under the Data Protection Act 2018, Registration No. Z2623868.

This policy applies to all data, in whatever form, relating to Accenian business activities worldwide, and to all data handled by Accenian relating to other organisations with whom it deals.

Personal information we may collect from you:

We Accenian collect the minimum amount of information about you that is commensurate with providing you with a satisfactory service. This policy indicates the type of processes that may result in data being collected about you.

We may collect and process the following data about the:

·       Information that you provide if you register on our website or place an order for data or data services together with the details necessary to administer your account, including any necessary compliance checks.

·         Information that you provide by filling in forms on our website and subscribing to the services available on our website.

·         Information that you provide to us when you write to us (including by email and fax) or when we speak to you by telephone.

·         Information that you provide to us by completing surveys or participating in competitions.

·       Details of your visits to our website and the resources you access to enable us to monitor and improve our service and to know which parts of our website are of most interest to our customers and visitors to our website.  

How we will use information about you:

We may collect any or all the information that you give us depending on the type of transaction you enter into, including your name, address, telephone number and email address, together with data about your use of the website. We process data differently depending on the category you fall under our services – Candidate Data, Client Data or Supplier Data.

We may use information about you in the following ways:

·        Registration details and customer information will be used to administer your account, to keep a record of which services you have subscribed to and to deliver the services you have requested.

·        To provide you with information about Accenian offers and services that you request from us or which we believe may be of interest to you, where you have consented to be contacted for such purposes. You have the right to ask us not to process your personal information for marketing purposes and if at any time you wish to opt out of such use then you may contact privacy@accenian.com.

·        To ensure that content from our website is presented in the most effective manner.

·        To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.  

·        From time to time we may also permit selected third parties to use your data to provide you with information about goods and services which may be of interest to you, provided that you have consented to third parties contacting you in this way. You have the right to ask us not to
process your personal information for marketing purposes and if at any time you wish to opt out of such use then you may contact privacy@accenian.com.

We do not sell or rent out personal information to any other organisations.

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about visitors to our website. For example, we may provide our advertisers with an anonymous summary of the demographics of visitors to our website
or with statistics relating to site usage.

If you do not want us to use your personal information in one or more of the ways mentioned above, please contact privacy@accenian.com.

Where we store and process your personal information:

Accenian is responsible for the processing of your personal information. 

Our technology services providers or other contracted service providers may also have access or store data for us, but solely for use on behalf of Accenian in accordance with our instructions and under our control. Secure credit card and payment authorisation is handled by our payment providers who also agree to these terms.

By submitting your personal information, you agree to this transfer, storing and/or processing. We will take all steps reasonably
necessary to ensure that your information is treated securely and in accordance with this privacy policy.

Your information will not be transferred abroad, but you may be able to access your own registration details over the Internet from
locations abroad. This privacy policy covers just processing by Accenian and does not cover any processing which may be carried out by your Internet service provider.

Disclosure of your information

·        We may disclose your personal information to third parties:

·        If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of business and/or other agreements; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations, such as credit reference agencies and fraud prevention agencies, for the purposes of
fraud protection and prevention, credit risk reduction and to pursue debtors in any other manner mentioned elsewhere in this policy.

Cookies

Your Internet browser has the in-built facility for storing small files- “cookies” – that hold information which allows a website
to recognise your account.  Our website takes advantage of this facility to enhance your experience to store preferences.  You have the ability to
prevent your computer from accepting cookies but, if you do, certain functionality on the website may be impaired. For more details of our cookie
policy, please visit www.accenian.com/cookie-policy/

Changes to This Policy

Any changes to our Privacy Policy will be placed here and will supersede this version of our Policy.  We will take reasonable steps to draw your attention to any changes in our Policy if you are on our mailing list.  However, to be on the safe side, you should read this document each time
you use the website to ensure that it still meets with your approval.

Long Version

Who Are We?

Accenian is a specialist search and selection firm who operate in the UK. Our consulting services are within the Pharmaceuticals and our
opportunities are on a contractual or permanent basis. 

Our GDPR Sponsor and GDPR Lead representatives can be contacted directly here for all our office location:

GDPR Lead – Anna Krecisz

Email -Anna.Krecisz@eximius.com

Phone – 0207 648 6991

 

GDPR Sponsor – Nick Harrington

Email -Nick.Harrington@eximius.com

Phone – 0207 648 6950 Or alternatively at privacy@accenian.com

The Personal Data We Would Like To Collect From You and Process On Are:

Candidate Data:

Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed
below to enable us to offer you our consulting services which are tailored to you and your interests:

·        Full Name

·        Contact details;

·        Age/date of birth;

·        Gender;

·        Photograph;

·        Marital status;

·        Education details;

·        Employment history;

·        Professional Qualifications;

·        Emergency contacts and details of any dependants;

·        Referee details;

·        Immigration status (whether you need a work permit);

·        Nationality/citizenship/place of birth;

·        A copy of your driving licence and/or passport/identity card;

·        Financial information (where we need to carry out financial background checks);

·        Social security number (or equivalent in your country) and any other tax-related information;

·       Information for Vetting checks;

·        Diversity details including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information;

·        Details of any criminal convictions;

·        Details about your current remuneration;

·        Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website;

·     Extra information that your referees chooses to tell us about you;

·        Extra information that our Clients may tell us about you, or that we find from other third party sources such as job boards;

·        The dates, times and frequency with which you access our services;

·        CCTV footage if you attend our premises; and

·        Any additional information you choose to tell us. 

Client Data:

We process client data but actually store relatively limited amount of information. The necessary details we store are names, telephone numbers and email addresses. We intend to hold only the minimum amount of data needed with our clients to foster a successful relationship.

Supplier Data:

We process our supplier data but actually store relatively limited amount of information. The necessary details we store are names, telephone numbers, email addresses and the relative payment details that we might need to pay you. We intend to hold only the minimum amount of data needed with our suppliers to foster a successful relationship.

The Personal Data We
Collect Will Be Used For The Following Purposes:

·        Consulting Activities

·        Marketing Activities

·        Legal Claims

Candidate Data:

Consulting Activities

Our main services at Accenian are consulting activities as we try and fill opportunities with candidates that are presented to us by our clients on contractual basis. The purposes for the use of your personal information are in the list below:

· Collecting your data from you and sources, e.g. LinkedIn, Telephone, Email.

· Processing and storing your data on our database so we can contact you in relation to a relevant role.

· Comparing data about you to opportunities that might be a suitable option for you.

· Sending your data to our clients in relation to a job application or eligibility.

· Your data will be processed from any contract entered between you and us.

· Your data will be processed from any contract entered between Accenian and third parties in relation to your contractual process.

· Processing our payroll and invoices operations.

· Using your data to enable us to send you targeted marketing materials or other communications that we think will be relevant to you.

Marketing Activities

We may send you information for purposes that we think might be of interest to you, in aid of connecting candidates to job roles, such as:

·        To market our consulting services to you.

·        To send you detailed reports on market conditions, promotional offers, client’s events and emergency opportunities.

·        Promote marketing offers that we may have on for a period of time (consent given).

Certain marketing activities will require consent to be given if some of these activities do not fall under a legitimate interest and depending on the scenario we will ask for you to opt-in for our marketing purposes by subscribing to our email send outs.

There is also a ‘soft opt in’ option where we might send you information via previously-obtained details, due to the fact that you have been
affiliated with us in the past. Our marketing activities will only be similar to that of the past and we will offer you a clear
and simple
privacy@accenian.com option upon receiving.

Our marketing activities are based on what our candidates and clients would be interested in. If this is not of interest to you then you
can withdraw your consent and also opt out of our marketing interests. 

Legal Claims

In certain situations we may use your data to prepare or exercise legal claims against us. 

Client Data:

Consulting Activities

Our main services at Accenian are consulting activities through administering candidates to you on a contractually through us. Some of
the purposes of using your data are below:

·        Storing your details and data on our database so we can contact you in regards to candidates that we feel may be of interest to you.

·        Keeping records of our conversations on our databases so we can record and offer a bespoke service to you.

·        Processing your data for our targeted marketing campaigns.

We possibly may use your data if it is deemed to be necessary for our legitimate interests, stated below. If this is not something
you would like to have, you have the right to object. 

Marketing activities

We will not seek your consent when sending you marketing content to a corporate post address or email address. If you wish to no longer
receive our marketing information then please find out more and opt out of our marketing communications by emailing privacy@accenian.com.

Legal Claims

In certain situations we may use your data to prepare or exercise legal claims against us.

Supplier Data:

We only use your data for the following activities, for our suppliers and those who are operating with Accenian:

·       To store your data on our database so we can contact you regarding our current contract, agreement or relating to a past issue.

·        To retain or gain support from you in our services.

·        Help us to offer a tailored marketing approach

·        In certain situations we may use your data to prepare or exercise legal claims against us.

We may use your data if it is deemed to be necessary for our legitimate interests.

In any event, we are committed to ensuring that the information we collect and use is appropriate and accurate for this purpose, and does not
constitute an invasion of your privacy.

In terms of being contacted for marketing purposes Accenian would contact you for additional consent. We will not seek your consent when sending you marketing content to a corporate post address or email address. If this is not something you would like to have, you have the right to object.

Our Legal Basis for Processing your Personal Data:

Legitimate Interests

Article 6(1)(f) gives you a lawful basis for processing where “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data
subject which require protection of personal data, in particular where the data subject is a child.”

Candidate Data:

We believe that if you are under contract with us, in the process of starting a contract with us (contract placements), then it is necessary for us to acquire your personal data through purposes of legitimate interest. We normally would like to check the information you have provided to us or to confirm references, qualifications and any criminal checks to the extent that it is appropriate with local laws.

To carrying on providing our services, to you our candidates, we need to process your data for internal administrative duties, for example payroll or invoicing. As a result this falls under the purposes of legitimate interests, as you the candidate, are under a contract (contractors) with us.

If we believe that you are looking for employment or we have received your personal data from a job board where you have uploaded your
personal data, and you match some of the opportunity we have from our clients, then if we contacted you, this would fall under the purpose of legitimate interest for processing your personal data.

We also want to offer detailed opportunity recommendations that are tailored to you, to aid your search. As a result we believe it is appropriate for us to process your data to make sure you receive the most tailored content which in turn falls under the purpose of legitimate interests for processing your data.

If certain specific obligations fall on us, then by law, we have a legitimate interest to share your data with certain crime detection, tax collection or any litigation purposes. 

Client Data:

To ensure we foster a well working relationship with our clients, we store your personal data/or the personal data of individual contacts, for each specific client of ours on a CRM database. This is also used to store records of our conversations, meetings, opportunities and placements with you. As a result we deem your data to be necessary in our relationship with you, which falls under our legitimate interests as we provide our executive search and consultancy services to you.

Supplier Data:

We store data from individuals from our suppliers in order to warrant the services that you offer to us as our suppliers. We will also hold your financial data because we will need to reimburse you for your services. As a result we deem it to be within the scope of legitimate interest
as a legal basis for processing your personal data as we are a beneficiary of your services.

Your Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. 

Consent is required for Accenian to process both types of personal data, but it must be explicitly given. Where we are asking for your sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent to process your personal data for certain activities or for consent in our marketing activities at any time by emailing privacy@accenian.com or in writing to us at 50 Mark Lane, London, EC3M 7QR.

Disclosure of Your Information

Accenian collects and processes information from our clients, candidates and other third parties with whom we do business with. Primarily we also share your data with prospective clients to increase your chances of matching to a relevant vacancy listed. We may also share your data with third parties, our service providers, to provide you with the best possible service from us.

Retention Period

Accenian processes personal data for a period of 3 years and will store personal data on our systems for that period of time unless the law or any other regulation requires us to keep that data (for example, any obligations with the tax authorities or in any connection to possible litigation). 

Your Rights as A Data Subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

●  Right of access – you have the right to request a copy of the information that we hold about you.

●  Right of rectification – you have right to correct data that we hold about you that is inaccurate or incomplete.

●  Right to be forgotten – in certain  circumstances you can ask for the data we hold about you to be erased from our records.

●   Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

●   Right of portability – you have the right to have the data we hold about you transferred to another organisation.

●   Right to object – you have the right to object to certain types of processing such as direct marketing.

●  Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated  processing or profiling.

●  Right to judicial review: in the event that Accenian refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.

All of the above requests will be forwarded on should there be a third party involved (as stated above) in the processing of your personal data.

Please download the Subject Access Request form and send it to us in writing if you would like to understand what data we hold on you.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Accenian (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority of Accenian’s data protection representatives reachable at privacy@accenian.com.

The details for individual contacts are:

GDPR Lead – Anna Krecisz

Email -Anna.Krecisz@eximius.com

Phone – 0207 648 6991

GDPR Sponsor – Nick Harrington

Email -Nick.Harrington@eximius.com

Phone – 0207 648 6950

Or alternatively at privacy@accenian.com