THE SOMERS PARTNERSHIP - PRIVACY POLICY
The Somers Partnership Ltd (SPL) processes personal data to deliver executive search, recruitment and related advisory services. SPL is registered with the UK Information Commissioner’s Office (ICO) as a Data Controller under registration number Z9781657. This policy explains how we collect, use, store and protect personal information in accordance with the UK GDPR, the Data Protection Act 2018 and all applicable privacy laws. By using our services, you consent to the practices described in this policy.
What personal data we collect
We collect and process personal data including: contact details, CVs, professional profiles, career history, interview notes, assessment information, compensation data, references, communication records and any information necessary for recruitment and advisory work. We may also collect information from publicly available sources such as LinkedIn, company websites, press releases, regulatory filings and professional publications.
We do not intentionally collect information relating to children.
Sensitive data
We may process special category data only where necessary and lawful, such as with explicit consent, where required by law, or where the data is voluntarily provided for recruitment purposes (for example information relevant to workplace adjustments).
How and why we use personal data
We process data only when there is a lawful basis to do so. The primary lawful basis for our work is legitimate interests, specifically SPL’s legitimate interest in providing executive search and recruitment services to clients and in connecting candidates with relevant career opportunities. Other lawful bases include consent where this is appropriate, fulfilling our contractual obligations to clients and meeting legal or regulatory requirements.
We use personal data to:
- assess suitability for roles and identify relevant opportunities
• introduce candidates to clients
• manage search processes and maintain accurate records
• conduct interviews, assessments and background verifications where appropriate
• communicate with candidates, clients and sources
• improve our services and maintain business continuity
• comply with legal, regulatory and audit requirements
Telephone and online communications
We may record telephone calls, online meetings and video conferences (including Teams, Zoom and similar platforms). Recordings are used solely for internal business purposes such as maintaining an accurate record of discussions, supporting service quality and assisting in the delivery of our recruitment work. These recordings are held securely and with the same protections described throughout this policy. They are accessible only to authorised personnel and are not shared with third parties except where required by law or expressly agreed. If you prefer a call not to be recorded, please inform us at the start of the conversation.
Data obtained from third parties
We may receive information from clients, referees, professional sources, public databases, research tools and licensed information providers. This supports our ability to identify, assess and contact individuals who may be suitable for executive search assignments.
Sharing your data
We may share personal data with:
• clients and prospective clients, but only where relevant to a specific assignment or where you have expressed interest
• professional advisers and assessment providers
• third-party service providers such as IT, CRM, cloud hosting, email, video conferencing, and security services all of whom operate under data processing agreements
• regulatory or legal authorities where required
Use of third-party service providers
We use trusted third-party service providers to support our communication, recording, IT and data-hosting systems. These providers are expected to maintain strict security and privacy standards and process personal data only under our instructions and in compliance with applicable data protection laws.
International transfers
If data is transferred outside the UK, we ensure appropriate safeguards are in place, such as the ICO International Data Transfer Agreement (IDTA), the EU Standard Contractual Clauses (SCCs) or other legally recognised mechanisms.
Security of personal data
We use technical and organisational measures to protect data, including encryption, access controls, secure hosted infrastructure, password protection, monitoring systems and confidentiality obligations for employees and contractors.
Data retention
We retain personal data only for as long as necessary for recruitment, business, and legal purposes. Candidate data is generally retained while it remains relevant for executive search activity, unless you request deletion. Client and business records may be retained for statutory periods. Recordings, notes, emails and related materials are kept only for as long as they are needed for the purposes for which they were created.
Your rights
Under the UK GDPR, you have the following rights:
• access your data
• request correction of inaccurate data
• request deletion of your data
• request restriction of processing
• request transfer of your data to another organisation (data portability)
• withdraw consent at any time where processing is based on consent
• lodge a complaint with the Information Commissioner’s Office (ICO)
If you request deletion, we may retain a minimal “Do Not Contact” record to ensure your preference is respected.
Marketing communications
We may send you updates, insights
or event information relevant to our work. You may opt out at any time using the unsubscribe link or by contacting us.
Cookies and website information
If our website uses cookies or analytics tools, these will be explained in our Cookie Policy. You can manage cookie preferences through your browser settings.
How to contact us
To request access to your data, update your information, exercise your rights, or ask questions about this policy, please contact: enquiries@somerspartnership.com
