Privacy Policy
Data Privacy Statement
effective from Nov 1, 2018
Metin Mitchell & Co (“Data Protection Statement”)
Protecting your Personal Data is something we take very seriously. This statement is intended to give you an overview of how we ensure this protection, what kinds of data we collect and why, and how we deal with such personal data we will collect from the effective date of this privacy policy Nov 1, 2018 onward.
Metin Mitchell & Co. is committed to keeping your information secure and managing it in accordance with our legal responsibilities as relevant to our business required under privacy and data protection laws applicable wherever we operate in the world.
Personal Data means any information relating to an identified or identifiable natural person – the Data Subject. An identifiable natural person is one who can be identified, directly or indirectly, and in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, professional, cultural or social identity of that natural person.
Who Is Responsible?
Responsibility for data collection about Data Subjects and in connection with this Data Protection Statement is Metin Mitchell and Company DMCC, (The Dome Tower 8th Floor, Unit no. 805, Jumeirah Lakes Towers, Cluster N , P.O. Box 336566 ,Dubai, United Arab Emirates ) herein “MM&Co”, “we”, “us”.
For more detailed information about Metin Mitchell & Co and our Services, please refer to www.metin-mitchell.com or contact us.
• The Information We Collect
Metin Mitchell & Co is a leadership advisory and executive search firm which collects, uses and stores a variety of personal data about Data Subjects required to provide our Services. The nature of our services means we are required to process personal data quickly, confidentially and occasionally without reference to the data subject. Mostly we use data already available in the Public Domain. For any data collected and stored beyond such data as available in the Public Domain at collection time, we will seek the Consent of the Data Subject.
Executive Search Data
If you are a potential candidate for one of our executive search assignments, categories of personal data we collect may include: contact information (e-mail address, address, telephone number), career history, education history, social activities, compensation details (where permitted by applicable legislation), professional experience, languages, photographs, individual capabilities and preferences, personality, character traits, professional style profile, executive competencies, interview notes (if applicable), identification data (civil/marital status, gender, nationality), and contact history. This data may be obtained directly from you, through publicly available sources and/or third parties such as sources/referees, your professional networking profile, news reports and our authorized background check providers.
It is not Metin Mitchell & Co’s policy to seek any sensitive information about you unless done for legitimate recruitment purposes and we suggest that you do not provide information of this nature unless necessary.
Leadership Advisory 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 and interviews. Providing additional personal data such as age, gender, and ethnicity is voluntary and will not affect the assessment results.
Referee or Source Data
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 or Supplier Data
If you are a MM &Co client or supplier, 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 the contracted services).
• Where the Personal Data is Held
Personal information collected by Metin Mitchell & Co and data is processed by specialized Application and Data Hosting Service Providers contracted by Metin Mitchell & Co.
• How We Use 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 to provide our Services.
Candidate and Assessment Data
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 potential candidate to potential employers (Metin Mitchell & Co’s clients), contacting you for an assignment (executive search or assessment) or verifying the details of your profile.
Your personal information may also be shared with Third Parties who we have engaged to provide services such as education checks and/or background checks, to the extent that the checks performed are appropriate and in accordance with local legislation, as well as our third party service providers who perform functions on our behalf such as outsourced document storage providers, all of whom will be required to process your personal information in accordance with applicable data protection laws and this Privacy Policy. 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.
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 a matter of applicable law.
Referee or Source Data
We will use the data collected to obtain information regarding your experience with, and thoughts and opinion on a particular candidate or potential candidate. If a candidate provides us with your details as a Referee, we may share your contact information with our clients in order to allow our clients to evaluate a candidate for a specific position. Any reference, opinion or feedback you provide 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.
Client or Supplier Data
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.
Intellectual Capital
We may contact you from time to time to share intellectual capital and thought leadership that we have published when we believe it could be of interest to you or relevant to your role at your organization. You may opt out of receiving these 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.
• Where Does Data Go Once it is Collected by MM & Co
As a fundamental rule, we do not transfer, sell or otherwise market Personal Data to third parties, such as other companies or organizations for monetary reasons. We only share data with our clients under the obligations of our Services delivery.
External Service Providers
Data can also be accessed in purely technical terms by service providers and contract partners we use to operate our IT system. These external providers are required not to use your Personal Data other than to provide the services requested by us or otherwise in accordance with our instructions.
Intra-Organization Sharing
Within the Metin Mitchell & Co organization, there is a need to exchange Personal Data between employees and authorized contractors. For this reason, MM & Co will share your Personal Data within the organization for the purposes set out in this Data Privacy Policy. MM & Co entities might also be established outside the European Union or the European Economic Area. In such cases, we will ensure that there are adequate safeguards (i.e. EU standard data protection clauses) in place to protect and process your Personal Data. Data is accessible to Metin Mitchell & Co users, including employees and contractors involved in delivering Services.
Sending Data to Third Parties
We share Data Subject information with third parties as required for the diligent delivery of our services and only subject to prior and implicit consent granted by the Data Subject residing in the EU for a defined purposes or Client related assignment.
Please be aware that we are not responsible for the data processing activities of others, such as our clients.
Transfer of Data to different locations
Your Personal Data may be transferred to and processed by Third Parties in other countries where laws and provisions governing the processing of Personal Data may be less stringent. In such cases, we will ensure that there are adequate safeguards in place to protect your Personal Data in line with the stipulations of this data privacy policy.
• What are Your Rights as a Data Subject
In addition to the rights mentioned before in this document, Data Subjects have rights in relation to their Personal Data as listed below:
- request a copy of your Personal Data we hold about you
- ask that we update the Personal Data we hold about you, or correct any Personal Data that you think is incorrect or incomplete
- ask that we delete Personal Data that we hold about you, or restrict the way in which we use your Personal Data
- object to our processing of your Personal Data
- request your Personal Data be transferred to you or another data controller
If you want to exercise your Rights as a Data Subject, please contact us at info@metin-mitchell.com indicating the intent of your request.
If you are unhappy with the way we have handled your Personal Data or any data protection query or request that you have raised with us, you have a right to complain to the competent supervisory authority.
• How Long do we Retain your Personal Data
We store Personal Data according to legal storage periods. If not otherwise agreed, we store your data for an unlimited time.
We will delete or block your data should you revoke your consent.
• Security
The security of your data is important to us: so, all the areas of our websites where you can actively input data use encryption systems such as SSL (Secure Socket Layer) to protect your data against being accessed by unauthorized third parties.
In order to guarantee that the appropriate and suitable safeguards for the protection of your personal data are in place, in addition to the privacy practices set out in this Privacy Policy, Metin Mitchell & Co has established a set of binding internal rules related to processes and technical infrastructure. These rules are a commitment by Metin Mitchell & Co to adequately protect personal information of candidates and assessed individuals we process regardless of where the data resides.
• How to contact us
In case you have any questions please contact us at info@metin-mitchell.com
• Changes to this Data Protection Statement
This Data Protection Statement was put in place November 1, 2018. We may occasionally modify or amend it from time to time. When we make changes to this Data Privacy Statement we will update the revision date at the top of this Data Privacy Statement. Where those changes are material, we will take steps to let you know. The new modified or amended Data Protection Statement will apply from that revision date. Please always verify whether you have consulted the last version of the Data Privacy Statement
