1. Who We Are and What this Policy Is
Welcome to The March Partnership Ltd., International House, Holborn Viaduct, EC1A 2BN, United Kingdom and its subsidiaries in countries throughout the world (collectively ’March International’, ”we”, ”us” and ”our” etc.). We are an executive search and market advisory business. We provide a variety of services to these clients and other parties, including, but not limited to: (i) executive search; (ii) executive assessment, development, and coaching; (iii) new market analysis. For additional information on our Services please visit https://www.march-
We respect the privacy of our clients, candidates and other users of our services (”you”, ”your”) and are committed to protecting your personal data and information according to the applicable laws. This privacy policy (”Policy”) explains how to what extent and for what purposes we are collecting and subsequently processing personal data and information.
March International takes its responsibility for the processing of your personal data and information very seriously, whether provided to us on our website, via email, via social networking websites, in person or otherwise.
2. Definitions
In addition to terms defined elsewhere in this Policy, the following terms shall have the following meaning throughout this Policy:
”Candidate” means any candidate, interested person, or Client employee or board member, who is considered, evaluated, assessed or coached by March International in connection with the Services;
”Client” means any of the organisations or individuals who contract March International’s Services;
”Personal Information” means any information that either (a) personally identifies a natural person; or (b) pertains to an identifiable natural person, i.e. someone who can be identified, directly or indirectly, 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 his or her physical, physiological, genetic, mental, economic, cultural or social identity, or (c) constitutes individually identifiable information about an individual consumer collected by us online through our website and that we maintain in an accessible form, or that (d) we are otherwise required to protect under applicable data privacy laws (including, but not limited to, national, international and supranational data protection and privacy laws, directives, regulations, and comparable legal acts). Examples of Personal Information include your contact details such as your name, email address, birthday or phone number as well as information about your professional education and experience, skills, preferences, membership in professional organisations, etc.;
”Processing” (and variations such as ”Process”) means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, restriction, erasure or destruction; ”Sensitive Personal Information” means Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the Processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation;
3. Processing of Your Personal Information
As part of our Services, we specialise in the global search, integration, assessment, coaching, and development of Candidates for or in executive and similar management positions on behalf of our Clients, based on data held by or made available to March International (”Client Services”). In the event you are interested in becoming a Candidate for one of our Client Services, you can provide us with information on your personal and professional background (”Candidate Information”) that we may take into consideration as part of the relevant Client Services. For example, you may provide this information directly to one of our consultants, or upload your CV through our website.
Providing any Candidate Information is purely voluntary on your part. Although it is generally true that, the more information you share with us, the better we are able to assess you and/or your potential suitability for or within an executive or similar management position, we urge you not to disclose to us any Candidate Information that is likely of little or no relevance for the respective Client Service.
If and to the extent you share Candidate Information with us, we might follow up with you using the contact details you may have provided in order to clarify any questions we might have or obtain complementary information from you. If you are a Candidate for Client Services relating to executive search, we might in addition (i) conduct assessments of your professional profile and perform searches for information on your personal and professional life publicly available via social media services, on the Internet, or within data you have previously disclosed to us, provided that such information might be of importance for the relevant Client Service), whereby we take appropriate measures to ensure that such third party data providers are legally permitted or required to disclose such information to us. Any resulting information will be considered Candidate Information and be Processed as described below together with the Candidate Information you initially provided us with.
Depending on your interaction with us, your Personal Information may be Processed as follows:
3.1 For Client Services
Your Candidate Information Processed by March International and/or selected March International partners might contain (a) your contact details (name, address, phone number, email address, etc.), (b) your biographical data, (c) information on your professional education, (d) your educational credentials, professional diplomas and certificates, and (h) any Sensitive Personal Information you might choose and explicitly consent to disclose to us. If you are a Candidate for Client Services relating to executive search, your Candidate Information may, in addition, contain (e) your employment and compensation history, (f) data on your suitability for Client opportunities we compile as part of our assessments of your professional profile, (g) information on your personal and professional life publicly available via social media services or otherwise on the Internet, or from third-party data providers, that might be of importance in connection with the relevant Client Services.
As part of Client Services, your Candidate Information may be Processed for the purposes of:
providing Client Services on behalf of our Clients, which may include Processing of your Candidate Information within your own integration, assessment, coaching or development as part of respective assignments for our Clients; operating the databases your Candidate Information is stored in; and
analysing your information using analytical tools and comparing the results against other Candidates or potential Candidates, including categorisation of Candidates through profiles developed by the software, to assist us in conducting Client Services.
If you are a Candidate for Client Services relating to executive search, your Candidate Information may be Processed for the following additional purposes:
executing searches for potential Candidates on behalf of Clients that have an opening for an executive or similar management position, including, but not limited to, assessing your suitability for Client opportunities; introducing you to Clients as a Candidate; verifying your educational credentials, professional diplomas and certificates; and ensuring that you will not be recruited on behalf of another Client unless you request consideration for other opportunities;
informing you of open executive or similar management positions potentially suitable for you;
sending you information or materials that we believe you may find interesting, such as reports, research, invitations to networking events, or information regarding our Services, publications, and surveys; and
approaching you as a Client contact for the introduction of other Candidates or as a source of information about potential Candidates for third-party Clients.
At no point will your Candidate Information be used for purposes other than providing the Client Services for which your Candidate Information has been intended. Your Candidate Information will be Processed until you revoke your declaration of consent given when sharing Candidate Information with us. Upon the revocation of your declaration of consent, we will delete your Candidate Information from all databases.
Your Candidate Information will only be Processed by and on behalf of March International as follows:
Via our proprietary databases, your Candidate Information will be available to the consultants and administrative staff of March International in various countries worldwide for the purposes of providing the Client Services;
Your Candidate Information might be disclosed to selected partners with whom we may work on specific projects when providing Client Services;
If you are a Candidate for Client Services relating to executive search and subject to our discretion, we might disclose excerpts of your Candidate Information such as your professional education and employment history with particular Clients in order to confirm whether they might be interested in you as a Candidate with respect to an opening for an executive or similar management position they have informed us of. The information disclosed will be limited to what is necessary for this purpose. We will not disclose the entirety of your Candidate Information or otherwise introduce you to any Client in detail without first obtaining separate and specific consent from you.
In this context, please be aware that various companies of March International, most of the third-party service providers operating the database servers and some of our Clients or selected partners we might disclose excerpts of your Candidate Information to are located in countries outside of the European Economic Area (EEA) that have not been found by the European Union to provide an adequate level of protection of personal data, i.e. a level of protection of fundamental rights and freedoms that is essentially equivalent to that guaranteed within the European Union. Similarly, the countries your Candidate Information, or parts thereof, might be transferred to in accordance with the above may not be found to provide an adequate level of protection by jurisdictions outside of the European Union. However, we have taken appropriate safeguards to require that your Candidate Information will remain protected in accordance with this Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of Personal Information within the March International group of companies and our third-party service providers and selected partners, which require all of them to protect Personal Information they Process from the EEA in accordance with the European Union General Data Protection Regulation.
3.2 In relation to the use of our website
(a) Cookies
Our website makes use of cookies. Cookies are small text files downloaded by your Internet browser and stored on the device you use to access the website (e.g., your desktop computer, tablet or smartphone). Depending on their purpose, cookies log specific user-related information such as your user preferences, authentication information, security parameters, data concerning the device you access the website with and statistical information regarding your use of the website. Where necessary during your visit to the website or when revisiting the website, your Internet browser transmits the cookies including the contained information back to the servers they were initially downloaded from. The analysis and Processing of such information allow us to ensure the functionality of the website, improve your online experience and optimise the structure and content of the website.
The cookies we use can be categorised as follows:
Session Cookies: These are cookies that allow our website to collect information about what you do during a browsing session each time you visit the website. When connecting to our server, your device will be allocated a session ID, which enables our server to identify your device during the session and facilitates website usability. These cookies are temporary and are set to be deleted when you leave the website;
Persistent Cookies: These are cookies that are stored by your Internet browser for more than a session and are set to expire within a defined time period. Persistent cookies enable us to remember your settings and information, so you do not have to keep re-entering them whenever you visit our website. They also measure how you use and interact with the website and enable us to personalise the website. For example, they may allow us to alter the rotation of images on the website so that different images will be displayed on your next visit;
First-Party Cookies: These are cookies that we store and access on your device in our capacity as controller of your Personal Information when you visit our website. They might include cookies related to third-party service providers, provided that we control and determine the purposes and means of the Processing of your Personal Information logged by such cookies. As a result, first-party cookies might log user-related Personal Information accessible to and Processed by third parties on our behalf and subject to our instructions.
Third-Party Cookies: These are cookies that are stored and accessed on your device by third parties determining the purposes and means of the Processing of your Personal Information logged by such cookies.
You may influence the scope and extent to which we use cookies when you visit our website. In particular, you may prevent cookies from being stored on your device by adjusting the respective settings on your Internet browser. For more information on how to do so in the settings of your particular Internet browser, please see the following information:
Internet Explorer:
https://privacy.microsoft.com/
Chrome:
https://www.google.com/intl/
Safari:
http://www.apple.com/privacy/
4. Data Security
Protecting your Personal Information is important to us. We use appropriate technical and organisational measures and safeguards designed to help prevent unauthorised access, unlawful Processing, and unauthorised or accidental loss of your Personal Information. This includes, for example, the encryption of your communication with us over the website based on the Secure Socket Layer (SSL) protocol.
5. Your Rights
Subject to the applicable law, you have the right to (a) obtain information about your Personal Information we Process; (b) to request the correction or completion of incorrect Personal Information we Process; (c) to request the deletion of Personal Information we Process; (d) to object to our Processing of your Personal Information or to Restrict the way we Process such Information; and (e) to request to receive Personal Information in a structured, commonly used and machine-readable format and to ask us to transmit that Personal Information to you or directly to a third party. To make a respective request, please contact us directly
6. Retention of Your Personal Information
We will retain your Personal Information where we have an ongoing consent or legitimate interest to do so. Kindly note that once our relationship with you has ended, your Personal Information may still be relevant for our current or future legitimate business purposes, for example, we may be required to retain certain Personal Information: (i) for our business records; (ii) to be able to establish, exercise or defend our legal rights; (iii) to show that we are compliant with applicable laws; and (iv) to show that we have fulfilled or continue to fulfill our obligations towards our Clients in relation to assignments you may have been involved in.
7. Amendments to This Policy
From time to time we may change our business activities and/or our policies and procedures with respect to the Processing of Personal Information. Where appropriate in these cases, we will, subject to applicable law, revise, supplement, or replace this Policy. When the Policy changes, we will post the substitute version and change the effective date listed at the beginning of the Policy.
When required by applicable law, however, we may provide you with advance notice of any changes to this Policy and with an opportunity to object to such changes. If you exercise your right to object, the changes will not become effective with respect to your Personal Information, but your ability to use our Services may be terminated or impaired. We will explicitly notify you of the consequences of the objection or non-objection to the extent and in the manner required by law.