Data protection policy

Introduction

Lawton Gallagher Limited (trading as Altima) is registered in England, Company Number 04115357). Our registered address is at 123 Victoria Street, London, SW1E 6DE.

Altima is committed to being transparent about how it collects and uses the personal data of all individuals that it comes into contact with in the course of its business, and to meeting its data protection obligations. This policy sets out Altima's commitment to data protection, and individual rights and obligations in relation to personal data.

This policy applies to the personal data of potential candidates and candidates, referees, client contacts and other individuals that it comes into contact with in the search process, referred to below as ‘search-related personal data’.

Altima has appointed Emily de Sausmarez, Office Administrator, as the person with responsibility for data protection compliance within the organisation. Emily can be contacted at emily@wearealtima.com or on 02037453780. Questions about this policy, or requests for further information, should be directed to Emily.

Definitions

"Personal data" is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.

"Special categories of personal data" means information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.

"Criminal records data" means information about an individual's criminal convictions and offences, and information relating to criminal allegations and proceedings.

Data protection principles

Altima processes search-related personal data in accordance with the following data protection principles:

• Altima processes personal data lawfully, fairly and in a transparent manner.
• Altima collects personal data only for specified, explicit and legitimate purposes.
• Altima processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
• Altima keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
• Altima keeps personal data only for the period necessary for processing.
• Altima adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

Altima tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons.

Where Altima processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data.

Altima will update search-related personal data promptly if an individual advises that his/her information has changed or is inaccurate.

Personal data gathered during the search process is held securely and confidentially in hard copy or electronic format, or both, and on our case management and other IT systems (including email). The periods for which Altima holds search-related personal data are contained in its privacy notices to individuals.

Altima keeps a record of its processing activities in respect of search-related personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

Individual rights

As a data subject, individuals have a number of rights in relation to their personal data.

Subject access requests

Individuals have the right to make a subject access request. If an individual makes a subject access request, Altima will tell him/her:

• whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
• to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
• for how long his/her personal data is stored (or how that period is decided);
• his/her rights to rectification or erasure of data, or to restrict or object to processing;
• his/her right to complain to the Information Commissioner if he/she thinks the organisation has failed to comply with his/her data protection rights; and
• whether or not the organisation carries out automated decision-making and the logic involved in any such decision-making.

Altima will also provide the individual with a copy of the personal data undergoing processing upon request. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.

To make a subject access request, the individual should send the request to Emily de Sausmarez at emily@wearealtima.com. In some cases, Altima may need to ask for proof of identification before the request can be processed. Altima will inform the individual if it needs to verify his/her identity and the documents it requires.

Altima will normally respond to a request within a period of one month from the date it is received. In some cases, such as where Altima processes large amounts of the individual's data, it may respond within three months of the date the request is received. Altima will write to the individual within one month of receiving the original request to tell him/her if this is the case.

If a subject access request is manifestly unfounded or excessive, Altima is not obliged to comply with it. Alternatively, Altima can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which Altima has already responded. If an individual submits a request that is unfounded or excessive, Altima will notify him/her that this is the case and whether or not it will respond to it.

Other rights

Individuals have a number of other rights in relation to their personal data. They can require Altima to:

• rectify inaccurate data;
• stop processing or erase data that is no longer necessary for the purposes of processing;
• stop processing or erase data if the individual's interests override Altima’s legitimate grounds for processing data (where Altima relies on its legitimate interests as a reason for processing data);
• stop processing or erase data if processing is unlawful; and
• stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual's interests override Altima’s legitimate grounds for processing data.

To ask Altima to take any of these steps, the individual should send the request to Emily de Sausmarez at emily@wearealtima.com.

Data security

Altima takes the security of search-related personal data seriously. Altima has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.

Where Altima engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

Impact assessments

Some of the processing that Altima carries out may result in risks to privacy. Where processing would result in a high risk to individual's rights and freedoms, Altima will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

Data breaches

If Altima discovers that there has been a breach of search-related personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. Altima will record all data breaches regardless of their effect.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.

International data transfers

Altima will only transfer data to countries outside the European Economic Area (EEA) for the purposes of processing it on cloud based IT and case management systems. Data is transferred outside the EEA in accordance with the conditions set out in the GDPR and only to countries that have been certified by the European Commission as having an adequate level of data protection in place.

Individual responsibilities

Individuals are responsible for helping Altima keep their personal data up to date, particularly as individuals will be the source of much of the personal data that Altima holds.

Altima staff may have access to the personal data of other individuals, including candidates, clients and referees, in the course of their employment, contract, volunteer period, internship or apprenticeship. Where this is the case, Altima relies on individuals to help meet its data protection obligations to those other individuals.

Individuals who have access to personal data are required:

• to access only data that they have authority to access and only for authorised purposes in accordance with a legitimate business requirement;
• not to disclose data except to individuals (whether inside or outside Altima) who have appropriate authorisation;
• to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
• not to remove personal data, or devices containing or that can be used to access personal data, from Altima’s premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device; and
• not to store personal data on local drives or on personal devices that are used for work purposes.

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under Altima's disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing candidate or client data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.

Training

Altima will provide training to all staff about their data protection responsibilities at regular intervals.

‍