Executive search depends on discretion. This notice explains how Kleboe Ltd handles personal data about candidates and potential candidates, under the UK GDPR and the Data Protection Act 2018.
How we find you
Headhunting means we often approach people who have not applied for a role. We may find your details from public professional sources such as LinkedIn, company websites, industry press and conference listings, or through referrals from people in our network. When we first contact you, we will point you to this notice. If you would prefer us not to contact you again, tell us and we will respect that.
What we hold
- Name, contact details and current and previous roles.
- Your CV, career history, qualifications and achievements.
- Notes from our conversations, including your career goals, remuneration expectations and notice period.
- Assessment results and references, where you take part in a selection process.
- Right-to-work information, where a client requires it at offer stage.
We do not ask for special category data (such as health, ethnicity or religion) unless it is needed, for example to make reasonable adjustments to an interview under the Equality Act 2010. If so, we will ask for your explicit consent.
Why we use it, and our lawful basis
We rely mainly on our legitimate interests in identifying and introducing strong leaders to our clients, which we balance carefully against your privacy. Where you engage with a specific search, we also process data to take steps at your request before a contract (contract), and to meet our legal duties (legal obligation).
Who sees it
We will never send your details to a client without your agreement. This is a requirement of the Conduct of Employment Agencies and Employment Businesses Regulations 2003, and a matter of principle for us. We share data only with the client you have agreed to be introduced to, referees you have nominated, and service providers who support our business under contract.
Confidentiality
We treat every conversation as confidential. We will not tell your current employer that you are talking to us.
How long we keep it
We keep candidate records for up to 12 months after our last meaningful contact with you, so we can consider you for future roles. We review every candidate record every 12 months. After that, we delete or anonymise them unless you ask us to keep in touch.
Your rights
You can ask to see, correct or delete your data, or object to us processing it, at any time by emailing enquiries@kleboe.co.uk. You can also complain to the Information Commissioner's Office at ico.org.uk.
Our general privacy notice covers our controller details, international transfers and other points.