Privacy policy

Introduction                      

MontaRosa is a leadership search firm focused on helping our clients address their most fundamental business needs – advising on leadership; and talent identification, assessment, recruitment and succession planning. We are committed to protecting the privacy of your personal information and we summarise here our policies regarding the collection, use and transfer of your personal information, the security measures we employ to protect such data and your rights and choices with regard to access or use of such data.

MontaRosa

MontaRosa and our associated companies established in the European Union ("MontaRosa", "we", "our" or "us") hold and process data on all current and prospective applicants, interview candidates, interns, agency workers, consultants, directors and (where provided by you) third parties who may be connected to an employment search (e.g. referees, next-of-kin, emergency contact information and/or dependents) ("candidates" or "you" or "your").

The relevant associated company of MontaRosa on whose behalf you are will be the data controller of your personal information.  In addition, where processing of personal information is undertaken by other associated companies of MontaRosa for their own independent purposes, these associated companies may also be controllers of your personal information.  The contact details of each of MontaRosa's data controllers and, where applicable their representatives and relevant data protection contact, are available here.

You can contact MontaRosa regarding your personal information at mydata@montarosa.com or contacting the relevant data controller directly, using the link above.

Personal Information

We collect a variety of personal information in order to provide our advisory services.  Personal information means any information describing or relating to an identified or identifiable individual.  An identifiable individual is one 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 the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

It typically includes employment history, degree(s) and other qualifications, languages and other skills as well as contact information. It may also include, age, nationality and gender, compensation details, a record of our contact history with you and comments, views or references from third parties.

We advise you not to provide information which may be deemed sensitive (such as special categories of personal information or data relating to criminal records and information regarding criminal offences or proceedings) on your CV as we will retain any documents that you have provided to us.  Special categories of personal information means information relating to such matters as racial or ethnic origin, religious beliefs, physical or mental health (including details of accommodations or adjustments), trade union membership, sexual orientation, information regarding sexual life, biometric data and genetic data.

Your personal information may also be used anonymously and in the aggregate in order to put together industry, marketing and employment statistics. Used in this matter, your personal information becomes non-identifying and is no longer "personal information".

Sources of Personal Information

Some of the personal information that we process will be provided to us by you.  You will usually provide this information directly to us through dialogue including in-person, via phone and via electronic mail.  In addition to information provided by you, we may gather information from LinkedIn, Google, Company websites, press and periodicals and other publicly available sources.  We may also process personal information about you that we receive from indirect referees, colleagues, former employers, former colleagues, or your business contacts.  Where we ask you to provide personal information to us on a mandatory basis, we will inform you of this at the time of collection and in the event that particular information is required by the contract or statute this will be indicated.  Failure to provide any mandatory information will mean that we cannot carry out certain exercises on your behalf.  In some cases it may mean that we are unable to continue with your candidacy as we will not have the personal information we believe to be necessary to manage the same.

To find out more about the sources of your personal information, please contact mydata@montarosa.com.

Use and Processing of Personal Information

By choosing to provide MontaRosa with your personal information you indicate your willingness to share and have your information stored by MontaRosa and to be considered, when appropriate, for one of MontaRosa’s confidential executive searches.  However, we are not relying on your consent as a basis for processing this personal information unless you are notified otherwise, subject to applicable laws.

Your personal information are collected and processed for various business purposes in accordance with applicable laws. Personal information may occasionally be used for purposes not obvious to you where the circumstances warrant such use (for example in investigations).  We will collect and process your personal information for various purposes, as set out in this privacy notice. 

Where applicable data protection laws require us to process your personal information on the basis of a specific lawful justification, we generally process your personal information under one of the following bases:

  • the processing is necessary for the legitimate interests pursued by MontaRosa (being those purposes described in below), except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information;
  • the processing is necessary for compliance with a legal obligation to which MontaRosa is subject; or
  • the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract.

We may on occasion process your personal information for the purpose of the legitimate interests pursued by a third party (such as a prospective employer), except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information.

 

Purpose for processing

Lawful basis

a)     

Recruitment and executive search

 

This processing is necessary to take steps at your request to enter a contract of employment.

 

This processing is also necessary for the purpose of the legitimate interests pursued by MontaRosa. MontaRosa considers that it has a legitimate interest in managing its executive search business.

 

Further, this processing is necessary for the purpose of the legitimate interests pursued by MontaRosa's clients in fully assessing talent for employment to ensure that only suitable and appropriate candidates are both assessed and selected for their vacancies. 

 

b)     

Appropriate vetting for recruitment and executive search including, relevant employment history, relevant regulatory status, professional qualifications, and educational and vocational verifications

 

This processing is necessary for the compliance with legal obligations to which MontaRosa or its clients are subject.

 

This processing is also necessary for the purpose of the legitimate interests pursued by MontaRosa. MontaRosa considers that it has a legitimate interest in managing its executive search business.

 

Further, this processing is necessary for the purpose of the legitimate interests pursued by MontaRosa's clients in managing their business operations in the most effective way and attracting high calibre employees.

 

 

Access to Personal Information

In terms of providing information about you to our clients in the course of our business, summary biographical data may be shared with a client in the context of a particular search, for example to identify the most highly qualified and talented individuals within the markets we serve or to illustrate a typical profile within the individual search parameters. No representation is made about your interest or availability to contemplate such a role at this stage. Before presenting further details or indicating any potential interest you might have, we would make direct contact with you.

Within MontaRosa, your personal information can be accessed by or may be disclosed internally on a need-to-know basis to:

  • local, regional and global employees including managers and team members;
  • system administrators; and
  • where necessary for the performance of specific tasks or system maintenance by staff in MontaRosa teams such as the Finance, IT and the Global HR information systems support team.

Certain basic personal information, such as your name, location, job title, contact information and any published skills and experience profile may also be accessible to other employees of MontaRosa. The security measures in place within MontaRosa to protect your data are set out below.

Your personal information may also be accessed by third parties whom we work together with (including without limitation including AM Research Services, Prospect City, Macktez, Right Aligned and their associated companies and sub-contractors) for providing us with services, such as hosting, supporting and maintaining the framework of our IT systems.  Personal information in these systems may also be shared with certain interconnecting systems within our business. Data contained in such systems may be accessible by providers of those systems, their associated companies and sub-contractors.  

Further examples of third parties with whom your data will be shared include IT administrators, consultants and other professional advisors.   MontaRosa expects such third parties to process any data disclosed to them in accordance with applicable law, including with respect to data confidentiality and security. Where these third parties act as a "data processor" (for example, an IT contractor), they carry out their tasks on our behalf and upon our instructions for the above mentioned purposes. In this case your personal information will only be disclosed to these parties to the extent necessary to provide the required services. 

In addition, we may share personal information with national authorities in order to comply with a legal obligation to which we are subject. This is for example the case in the framework of imminent or pending legal proceedings or a statutory audit.

Data Security and Integrity

We use our best efforts to ensure that data is accurate, complete, current and reliable for its intended use. We use appropriate technical and organisational measures and safeguards to help protect your personal information from unauthorised access, misuse, alteration or loss. Our internal policies and procedures are designed to help ensure we safeguard the privacy and accuracy of all data we collect or process. To the extent that we disclose personal information to clients or third parties, we will request that they properly protect the security and confidentiality of such information and otherwise process such data in accordance with applicable law.

How Long We Keep Personal Information

MontaRosa has policies in place to regarding the retention of personal information.  This policy contains guidance regarding  retention practices, secure deletion and the use of anonymisation where deletion is not possible.  In accordance with these policies, personal information will be retained for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons.  In the absence of any other applicable period or legal requirement, we generally keep candidate records for no longer than 20 years after which the practices regarding deletion contained in the applicable policies will apply.

Overseas Transfers

From time to time your personal information (including special categories of personal information) will be transferred to associated companies of MontaRosa for the purposes described in this privacy notice.

These associated companies may be located within the European Union and elsewhere in the world, including the United States of America, Switzerland, United Kingdom, India, New Zealand, and Australia.   

As a result, your personal information may be transferred to countries outside of the country in which you live to countries whose data protection laws may be less stringent than yours.  MontaRosa will ensure that appropriate or suitable safeguards are in place to protect your personal information and that transfer of your personal information is in compliance with applicable data protection laws. 

Where required by applicable data protection laws, MontaRosa has ensured that service providers (including other MontaRosa associated companies) sign standard contractual clauses as approved by the European Commission or other supervisory authority with jurisdiction over the relevant data exporter.  You can obtain a copy of any standard contractual clauses in place which relate to transfers of your personal information by contacting mydata@montarosa.com, although some details may be redacted for confidentiality reasons.

Your rights

MontaRosa aims to ensure that all personal information are correct. You also have a responsibility to ensure that changes in personal circumstances (for example, change of address) are notified to MontaRosa so that we can ensure that your data is up-to-date. 

You have the right to request access to any of your personal information that MontaRosa may hold, and to request correction of any inaccurate data relating to you.

You also have the following additional rights:

  • Data portability - where we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for processing, and that personal information is processed by automatic means, you have the right to receive all such personal information which you have provided to MontaRosa in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
  • Right to restriction of processing - you have the right to restrict our processing of your personal information where:
    • you contest the accuracy of the personal information until we have taken sufficient steps to correct or verify its accuracy;
    • where the processing is unlawful but you do not want us to erase the data;
    • where we no longer need the personal information for the purposes of the processing, but it is required for the establishment, exercise or defence of legal claims; or
    • where you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether MontaRosa has compelling legitimate grounds to continue processing.

Where personal information is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise or defence of legal claims.

  • Right to withdraw consent -where you have provided us with your consent to process data, you have the right to withdraw such consent at any time. You can do this by (i) in some cases deleting the relevant data from the relevant HR system (although note that in this case it may remain in back-ups and linked systems until it is deleted in accordance with our data retention policy) or (ii) contacting your local Human Resources contact.
  • Right to object to processing justified on legitimate interest grounds - where we are relying upon legitimate interest to process data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the processing of your personal information infringes applicable law.

For further information regarding your rights, or to exercise any of your rights, please contact mydata@montarosa.com.

Additional Privacy Notices

We may undertake certain processing of personal information which are subject to additional privacy notices and we shall bring these to your attention where they engage.

Changes to the Privacy Notice

MontaRosa reserves the right to modify or amend this privacy notice at any time and for any reason, as permitted by applicable law. Should we change our approach to data protection, you will be informed of these changes or made aware that we have updated the privacy notice so that you know which information we process and how we use this information.

This privacy notice was last updated and reviewed on 23 May 2018.