Who are we and what do we do?
NAL Consulting FZE provides executive search services to clients within the field of Financial Services who are looking to recruit talent for their businesses. We are headquartered in the United Arab Emirates with an additional representative office in London.
Headquarters address: SM-Office – C1-915A. Ajman Free Zone, Ajman, United Arab Emirates.
We are committed to keeping your information secure and managing it in accordance with our legal responsibilities under the privacy and data protection laws applicable wherever we operate in the world as well as the General Data Protection Regulation 2016/679 in the European Union.
- • who this policy applies to;
- • what personal data we collect about you;
- • where we collect personal data about you from;
- • how and why we use your personal data;
- • how long we keep your personal data for;
- • who we will share your personal data with;
- • the legal basis we have for using your personal data;
- • the effect of not providing the personal data requested;
- • what rights you have in relation to the data we hold on you.
Who does this Private Policy apply to?
We provide executive search services to a range of clients internationally. Further details of our services can be found on our website at www.nalassociates.com . This policy applies to you whether you are a candidate for one of our clients, a client or whether you are a source or a referee inspect of a candidate.
For purposes of this policy:
candidate(s) means an individual who is a candidate, applicant, potential candidate or employee of a client;
client(s) means any, business, firm, organisation, government body or individual that mandates us to perform any of our services;
a referee is a person who provides a personal or work reference in respect of a candidate and;
a source is a person who provides us with information or intelligence about a candidate.
What personal data do we collect about you?
We collect the information necessary to be able to assess your suitability and eligibility for an assignment on which we have been instructed. This information may include your CV, contact details, identification documents, educational records, work history, employment history, references and any other information that is provided by you throughout the course of an executive search.
We only collect sensitive personal data (such as visa status, nationality, gender and compensation) from you where you have given your explicit consent.
Where do we collect personal data about you from?
Clients expect that we identify the best individuals to fill roles within their organisations. We therefore need to research systems, online databases and other information sources and talk to many individuals. In addition to our clients, such people will include referees and sources to help inform our decision making process. We process such data in accordance with relevant data protection laws.
The following are the different sources we may collect personal data about you from:
- • From you. This is information you provide directly to us whilst you are searching for a new opportunity or during an assignment on which we are working.
- • Publicly available sources such as for example LinkedIn and company websites.
- • By reference or word of mouth. You may be recommended to us by persons such as
a friend, a former employer, a former colleague, or even a present employer.
How and why do we use your personal data?
For candidates, we use your personal data to match your skills, experience and education with a role that we are working on for a client. We will initially collect basic information on you such as contact details, your current role and work experience to date and then pass this on to our client that is looking to recruit. If you are selected by our client and therefore proceed to the next stage of the process, we shall then proceed to collect more information from and about you to include motivation.
We may also collect personal data from third-party databases and other public sources.
For clients, as well as basic contact information we shall also collect information about your role(s) and requirement(s) and other information provided to us by your organisation.
For sources and referees, we use your information to contact you about a candidate and in order to obtain a reference for them. We shall also collect information regarding your credentials as a source, details of your relationship and knowledge of a candidate and your opinions of that individual. We may obtain this information directly from you or publicly available information.
How long do we keep your personal data for?
We keep your personal data for as long as required to provide our services and in accordance with legal, tax accounting requirements. Where your personal data is no longer required, we shall securely erase your information.
NAL Consulting FZE has set a six-year time frame for processing and holding data (beginning May 25th, 2018). If there has been no communication between a data subject and NAL Consulting FZE during this time frame, then all records associated with that data subject will be deleted from the database. NAL Consulting FZE plans to review the data retention policy, as well as the six-year retention period for non-communicated data subjects, one year after GDPR has come into effect (May 25th, 2019). If you would like more information for specifics, or on the steps we are taking to clean the data we hold, please contact the data protection office at:
Who do we share your personal data with?
NAL Consulting FZE communicates your personal data to clients who wish to hire for a position that may be relevant to you. We may also use that personal data to inform you about key trends in the market-place that can increase your awareness about your industry. We provide our services to organisations around the world within the Financial Services Industry. Personal data that is classified as non-sensitive is also available for viewing by any NAL Consulting FZE employee.
We may also conduct checks on you to verify the information you have provided and where we do this we share your information with only the data protection team of NAL Consulting FZE.
What legal basis do we have for using your information?
For prospective candidates, referees and clients, our legitimate interest in your information is driven by the requirement to assess suitability for potential roles, to identify potential candidates, to conduct research of the markets within which we operate, and to contact clients and referees.
If you are shortlisted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as health information. We shall always ask for your consent before undertaking such processing.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary or withdraw your consent for the processing of your personal data, we may not be able to match you with available job opportunities or provide you with any relevant market intelligence.
Do we make automated decisions concerning you?
No. However, from time to time we may also carry out personality profiling on candidates with the candidate’s consent when the client requests that information as part of the interview process.
Do we transfer your data outside the EEA?
We may transfer your personal data to clients in countries outside the EEA. Furthermore the clients to whom we may provide candidate information to will often be international organisations. The privacy laws that apply in these countries outside of the EEA may be different from those in your home country. Where we transfer personal data outside of the EEA, we take steps to safeguard that information.
Keeping information secure
We invest significant resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and so we cannot be held responsible for unauthorised or unintended access that is beyond our control.
What rights do you have in relation to the data we hold on you?
You have legal rights when it comes to protecting your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
Such rights may well include the following:
The right to be informed
The right of access
The right to rectification
You are entitled to have your information corrected if it is inaccurate or incomplete.
The right to erasure
This enables you to request the deletion or removal of your information where there is no compelling reason for us to continue using it. There are exceptions to the right of erasure.
The right to restrict processing
You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information but may not use it further. A note will be made on your record to ensure the restriction is respected in the future.
The right to data portability
You have rights to obtain and reuse your personal data for your own purposes across different services. For example if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely without affecting its usability.
The right to object to processing
You have the right to object to certain types of processing including processing for direct marketing (i.e. if you no longer wish to be contacted with regards to potential opportunities).
The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
The right to withdraw consent
If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
We will act on requests and provide a detailed report of your information free of charge and will ask that you submit these requests by emailing: firstname.lastname@example.org
We act on reasonable requests for information free of charge. We may charge a fee to cover our administrative costs of providing the information for unreasonable/repeated requests. We will respond within 30 days of the request being sent. If we require longer to process your request we shall let you know.
Do we use ‘cookies’ to collect personal data on you?
We do not sell, trade, or (save as for set out in this policy) otherwise transfer to outside parties your personally identifiable information.
We do not include or offer third-party products or services on our website.
Keeping information secure
We invest resources to protect your personal data, from loss, misuse, unauthorised access, modification or disclosure. However, no system can be 100% secure and so we cannot be held responsible for unauthorised or unintended access that is beyond our reasonable control.
Information about others
If you provide us with information about individuals such as details of a referee or personal contact you must ensure that they have agreed to this. We would advise you to keep a record of their agreement provide them with a copy of, or link to, this Policy.
We keep this policy under regular review and update it from time to time. This policy was last updated in October 2018. Please review this policy periodically for changes.
How will we contact you?
We may contact you by phone, email or social media. If you prefer a particular contact means over another, please let us know.
How can you contact us?
If you have any questions about this policy or a complaint about how we have handled your data or would like to exercise your rights with respect your personal data then please contact our Data Protection Officer at: email@example.com