Venator Associates Ltd is an executive search consultancy specialising in the placement of Derivatives and Asset Management professionals. Venator Associates is committed to protecting the privacy of both our candidates and clients, and this Privacy Policy explains the steps we take to ensure that any information gathered about an individual is kept secure and confidential and is only used for the purposes for which it was originally collected and / or submitted. Please read this Privacy Policy carefully to understand how your personal information will be treated. By using our website, interacting with our staff, or submitting any personal information to us, you will be deemed to have read this Privacy Policy and consented to us storing and using your information.

 

As an executive search boutique Venator Associates Ltd processes personal data in relation to its own staff, work-seekers, and individual client contacts. In doing this we abide by the principles of the Data Protection Act (1998) and the General Data Protection Regulation (GDPR) legislation (2018) as set out below.

 

Venator Associates LTD holds data on individuals for the following general purposes:

1. Staff Administration.

2. Advertising, marketing and public relations.

3. Accounts and records.

4. Administration and processing of candidates’ personal data for the purposes of exploring career opportunities on projects that they have consented to be involved in.

 

The Data Protection Act (1998) and GDPR (2018) requires Venator Associates LTD as data controller to process data in accordance with the principles of data protection. These require that data shall be:

1. Fairly and lawfully collected and processed

2. Processed for limited purposes.

3. Adequate, relevant and not excessive.

4. Accurate.

5. Not kept longer than necessary.

6. Processed in accordance with the data subjects’ rights.

7. Kept securely.

8. Not transferred to countries outside the European Economic Area without adequate protection.

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When you submit any personal information to us, we will acknowledge your submission by contacting you directly with information about next steps in the recruitment process and include a link to our data protection and privacy policy.  Venator Associates will collect and store personal information such; as your email address, name, address, telephone number, education and work history, or any other information that may be contained within your CV / Career Resume / Social Media Profiles / or Media presence. We may also make a note of relevant interactions with you.

 

Under the Data Protection Act and GDPR legislation, Personal data is defined as data which relates to a living individual who can be identified from the data or from the data together with other information, which is in the possession of or is likely to come into possession of Venator Associates LTD.  Data may only be processed with the consent of the person whose data is held.  The definition of “processed” is obtaining, using, holding, amending, disclosing, destroying and deleting personal data. This includes both hard and soft copy data.

 

Data in respect of the following is “sensitive personal data” and any information held on any of these matters will not be passed on to any third party without the express written consent of the individual:

1. Any offence committed or alleged to be committed by them

2. Proceedings in relation to any offence and any sentence passed

3. Physical or mental health or condition

4. Racial or ethnic origins

5. Sexual life

6. Political opinions

7. Religious beliefs or beliefs of a similar nature

8. Whether someone is a member of a trade union

9. References

 

Personal Information and / or Personal Sensitive Information is collected so that we may provide you with a reliable and efficient recruitment services and assist you in your job search / exploration of a career opportunity. This data will also enable us to contact you accordingly.  We will provide you with a copy of all personal information we hold about you within a month of receiving such a request, in accordance with the relevant Data Protection legislation. Your information, in the furtherance of us providing you with an efficient service, will be reviewed and shared by consultants working within the Venator Associates organisation.

 

We may from time to time be required to pass on your personal information to third parties as part of the recruitment process but will only do so where you have agreed that we can share this information.  Your personal information will never be shared with a third party (client or candidate) without your consent. In addition data shall only stored and / or processed in situations where there is a legitimate business interest to do so. As a result the Venator Associates Data Protection and Privacy policy complies with GDPR (2018) Article 6 (Lawfulness of processing) via permission “F” and in most cases also Permission “A”. Article 6 (Lawfulness of processing) of the GDPR Legislation and its permissions are presented below for clarity:

 

Article 6 (Lawfulness of processing)

Processing shall be lawful only if and to the extent that at least one of the following applies:

 

A) The data subject has given consent to the processing of his or her personal data for one or more specific purposes;

B) Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

C) Processing is necessary for compliance with a legal obligation to which the controller is subject;

D) Processing is necessary in order to protect the vital interests of the data subject or of another natural person;

E) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

F) Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

 

Any requests for access to a reference given by a third party will be treated with caution even if the reference was given in relation to the individual making the request. This is because the person writing the reference also has a right to have their personal details handled in accordance with the Data Protection Act 1998, and not disclosed without their consent. Therefore, when taking up references an individual will always be asked to give their consent to the disclosure of the reference to a third party and/or the individual who is the subject of the reference if they make a subject access request. If they do not consent, then consideration will be given as to whether the details of the individual giving the reference can be deleted so that they cannot be identified from the content of the letter. If so the reference may be disclosed in an anonymised form.

 

Venator Associates Ltd also gathers information on all our users of our website on an aggregated basis. This information is used to analyse what the total usage levels are for the site, what areas of the site are most popular and what times of the day are most popular for using the site. This information is used to determine what improvements we can make going forward. This information is not passed to our clients and the data is used for internal purposes only.

 

As a specialist executive search consultancy focused in the placement of Derivatives and Asset Management market we gather and analyse information on individuals within this market across Europe.  We do so as we have a legitimate interest in this field and this is a business necessity to be able to develop the Venator Associates LTD business. Examples of such projects include Diversity studies, market mappings, bonus structure comparison pieces, and firm by firm compensation comparison documents. Individuals are never named in these documents, and any data presented is done so in the form of ranges or averages.

 

Venator Associates LTD retain information regarding candidates, clients, and recruitment activity for the duration of an individuals’ career, and this can be for up to 40 years.  The data that we hold is reviewed at least every 5 years and we are in regular communications with all our contacts within our specialist area.

 

We are at all times bound by the provisions of the Data Protection Act (2003), and from May 2018 the provisions of the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679). The privacy policy is being updated at this time and we will have further updated in the coming months.

 

All information provided to us is ‘personal data’ under the Data Protection Act and the new General Data Protection Regulation (GDPR) guidelines and principles. When processing this data we follow the principles and guidelines as set out in the Data Protection Act and GDPR act.

 

Relating to security of data, Venator Associates LTD’s staff are permitted to add, amend or delete personal data from Venator Associates LTD’s database(s) (“database” includes paper records or records stored electronically). All staff are responsible for notifying those listed where information is known to be old, inaccurate or out of date. Our data security is obtained by secured and protected local databases, isolated disk drives, and remote servers. We engage the following corporate groups for advisory and services to this end:

1. Herts IT

2. Dillistsone Group

3. Norton AntiVirus / Symantec Corporation

4. Google LLC

5. Microsoft Corporation

 

If you have any questions relating to this Privacy Policy or how we use the personal information we have about you, please contact Sam Melhuish ( s_m@venator-associates.com )as Venator Associates LTD’s senior consultant with responsibility for Data Protection & Privacy within the group.  Data subjects, i.e. those on whom personal data is held, are entitled to obtain access to their data on request. All requests to access data by data subjects i.e. staff, members, customers or clients, suppliers, students, etc. should be referred to Sam Melhuish.