Updated January 2020
The data sets we primarily accumulate and hold fall into three broad kinds:
Information you give to us: When reviewing, accessing or using the Services, you may be asked to provide us with personal registration information which would include some or all of the personal data types listed above.
Information we collect about you: As is true of most websites and recruitment businesses, it is possible to gather information about you from computer-based sources such as your Internet Protocol (IP) address, browser type and operating system.
We may receive information about you from third parties including, for example, business partners, corporate clients, social media platforms and mobile applications and our network of searchers and freelance consultants.
This is in addition to publicly available information about your background, career history, that may be available on social media and elsewhere and which our researchers are able to verify and collate.
This information may be used to allow us to maintain our business relationship with you and provide all manner of support and service to you. We essentially hold your personal data to maintain our relationship with you now and into the future, especially given the nature and duration of modern careers and the changes that can and do occur within someone's career path.
We use your personal data to align candidate experience, skills and education with an assignment we are running.
If you are a referee, we use your information to contact you about a candidate and obtain a reference on them.
If you are a corporate client (such as a large employer which needs to attract and retain talent on an ongoing basis), we use personal data to allow us to fulfil our contractual obligations with you.
You will notice that we insist on very clear, affirmative action from you to signify your consent to our processing your personal data when you register with us (especially for any special category data which is always of a sensitive nature). We also have a compelling need to process your data in order to fully perform our contractual terms and conditions with our corporate clients and with you as a registrant or applicant. From time to time we will also process your personal data where we need to comply with other legal obligations - for example connected with any regulatory requests made of us or in the conduct of litigation where we are compelled to assist a Court with a discovery request for our information.
Carbon does not collect or process any of your personal data unless it is satisfied that there is a legitimate interest established under the terms of Article 6 (2) of the GDPR. This means that we will continually update and assess our legitimate interests as a recruitment and search business as we have done when producing the latest version of this policy. We set out below our most recent assessment of our business needs against the three legal tests designed to satisfy the legitimate interest requirements under Data Protection Law:
We have completed this most recent assessment by concluding that our legitimate interest is prudently counterbalanced by the constant right of an individual to make a data access, cessation of processing or erasure request to us so that we can stop such processing as and when required.
You have the following rights, as a result of the latest data protection rules set out in the GDPR, in relation to your personal data:
As you will note above, you have the right to ask for a copy of any personal information that we hold about you in our records, to correct any inaccuracies and to update any out-of-date information. We will provide you with a copy of the personal data undergoing processing in electronic emailable form. Any additional copies will incur a fee to cover our reasonable costs (including the staff time to assist with this additional work). You can also ask us not to send you direct marketing communications (however please note that we may continue to send you service-related (i.e. non-marketing) communications). If you wish to exercise any of these rights, or wish to object to our use of your personal information, please write to or email:
Alastair Cockrem Carbon Leadership LLP
91 Wimpole Street
Except as described below, we will not share your information with any third parties.
We will only make your personal information visible to the organisations we are working with when you are put forward for an opportunity.
We do not sell your personal data to third parties, and we don't share it except as necessary to provide our services.
We may need to share your information with our corporate clients for them to assess your suitability for positions now and in future.
All other data that we share with third parties will be anonymised and aggregated, but will never identify you or your company.
We may use technologies such as cookies, web beacons, or scripts to gather information about how you and others interact with our Services. For example, we will know how many users access a specific area or features within our website or Gated Talent Portal and which links or features they clicked on. We use this information to understand and optimize how our site is used, improve our marketing efforts, and provide content and features that are of interest to you.
If you wish to cancel your registration or Gated Talent account with us or request that we no longer hold your personal information, contact us at email@example.com
Information we collect is unlikely to be but may be transferred to, stored and processed in any country or territory where one or more of our partners or third-party service providers (e.g. our hosting company Webflow) are located or maintain server facilities. We are acutely aware of data hosting solutions we deploy and how the world around us can change (and will maintain vigilance in respect of other territories especially in the context of the United Kingdom's withdrawal from the European Union). If in future your personal data may be subject to transfer outside the European Economic Area, we will take all steps reasonably necessary to ensure that your data is treated with no less protection than it would receive if transferred and stored within the EEA: we adhere to statutory appropriate safeguards relating to restricted transfers of information outside the EEA referred to at Article 46 of the GDPR.