Privacy Policy for Serpent Sourcing

At Serpent Sourcing, we are committed to protecting the privacy and security of the personal data of our website visitors, clients, and candidates. This Privacy Policy outlines how we collect, use, process, and protect your personal information in compliance with the General Data Protection Regulation (GDPR) and other applicable privacy laws.

1. Information We Collect

We collect various types of personal data to deliver our human resources consulting services. This data may include:

• Identity Data: Names, titles, dates of birth, gender, marital status, and nationality.
• Contact Data: Addresses, email addresses, telephone numbers, and professional social media links.
• Professional Data: CVs/resumes, employment history, educational background, skills, qualifications, salary expectations, references, and other information relevant to job applications or talent acquisition.
• Technical Data: Internet protocol (IP) addresses, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our site.
• Usage Data: Information about how you use our website, products, and services.
• Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.

2. How We Collect Your Information

We collect personal data through various methods:

• Direct Interactions: You may provide us your Identity, Contact, and Professional Data by filling in forms on our website, corresponding with us by post, phone, email, or otherwise. This includes data you provide when you:
  • Enquire about our services.
  • Apply for roles through our talent acquisition services.
  • Request marketing materials.
  • Provide feedback or testimonials.
• Automated Technologies or Interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies.
• Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties and public sources, such as professional networking sites (e.g., LinkedIn), job boards, referrals, or other publicly available sources, especially for talent acquisition and recruitment purposes.

3. How We Use Your Personal Data

We use your personal data for the following purposes and based on the following lawful bases:

• To Provide and Improve Our Services: To deliver talent acquisition and recruitment, HR strategy development, organisational design, performance management systems, compensation and benefits consulting, HR technology implementation, employee relations and mediation, and leadership development and training.
  Lawful Basis: Performance of a contract with you or to take steps at your request before entering into a contract, Legitimate Interests (to study how customers use our services, to develop them).
• To Manage Our Relationship With You: Including notifying you about changes to our terms or privacy policy, responding to enquiries, or asking you to leave a review.
  Lawful Basis: Performance of a contract with you, Compliance with a legal obligation, Legitimate Interests (to keep our records updated, to study how customers use our services).
• For Marketing: To send you relevant information about our services that may be of interest to you, where you have consented to receive such communications or where we have a legitimate interest to do so.
  Lawful Basis: Consent, Legitimate Interests (to develop our services and grow our business).
• To Improve Our Website: To administer and protect our business and our site, including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data.
  Lawful Basis: Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud).
• For Legal and Compliance Reasons: To comply with legal obligations, regulatory requirements, or to defend legal claims.
  Lawful Basis: Compliance with a legal obligation, Legitimate Interests (to protect our business interests).

4. Disclosure of Your Personal Data

We may share your personal data with:

• Internal Third Parties: Other companies within our group acting as joint controllers or processors, to provide IT and system administration services and to undertake leadership reporting.
• External Third Parties:
  • Service providers acting as processors who provide IT and system administration services, professional advice, or perform background checks.
  • Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
  • Government bodies and regulators where we are required to do so by law.
  • Prospective employers: For talent acquisition services, with your explicit consent, we will share your professional data with potential employers for specific job opportunities.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International Transfers

Some of our external third parties may be based outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

6. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

8. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

9. Third-Party Links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

10. Changes to the Privacy Policy

We keep our Privacy Policy under regular review. Any updates or changes will be posted on this page.

11. Contact Details

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

Serpent Sourcing

27B Cadogan Gardens

Knightsbridge,

London, Greater London

SW3 2RX

United Kingdom

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.