PRIVACY POLICY
NB Lemercier & Associés (collectively « NBL », « we » or « our ») takes your data privacy seriously and commits itself to protect the personal data it collects and processes in the frame of its business purposes in compliance with the EU regulation.
This Privacy Notice is intended to inform people integrating our data base (“You”) on how NBL uses personal data for the purposes of recruitment activities, governance advisory, executive search, executive assessment, and executive coaching. It explains who we are, how we collect, use and process your personal data in respect of our obligations in relation to your personal data.
Data controller
In accordance with the General Data Protection Regulation known as the GDPR (Regulation (EU) 2016/679 of the European Parliament and of the Council), the data controller is:
NB Lemercier & Associés
15, avenue de l’Observatoire
75006 Paris
Lawful basis for processing of personal data and purposes of such processing
Personal data You give us are exclusively used for the following purposes:
- The handling of your recruitment, assessment or coaching
- The appraisal and assessment of your professional skills and experiences
- The presentation of your profile to a client in the frame of an assignment NBL is awarded, and
- The potential follow-up of your professional career.
To pursue its business purposes, NBL:
- Collects and processes personal data given by You or received from other sources (LinkedIn,…)
- Assesses your professional profile to complete the recruitment process and fulfil its responsibilities towards You and its clients
- Stores your personal data and updates it in our data base if necessary
- Shares your personal data with its clients to introduce your professional profile or submit your candidacy to a job position
- Double checks and asks for information about You while securing a reference (NBL exclusively uses the contact details provided by You) or verifying your education background (qualification, diplomas, …)
- Follows up on your professional career.
Your personal data has to be held and processed on a lawful basis as mentioned by Article 6 of the GDPR.
In particular, personal data processing is lawful when it is necessary for the purposes of the legitimate interests pursued by the data controller except where such interests are overridden by your interests or fundamental rights and freedoms.
Recital (47) of the GDPR says “The legitimate interests of a controller, including those of a controller to which the personal data may be disclosed, or of a third party, may provide a legal basis for processing, provided that the interests or the fundamental rights and freedoms of the data subject are not overriding, taking into consideration the reasonable expectations of data subjects based on their relationship with the controller.
Such legitimate interest could exist for example where there is a relevant and appropriate relationship between the data subject and the controller in situations such as where the data subject is a client or in the service of the controller. At any rate the existence of a legitimate interest would need careful assessment including whether a data subject can reasonably expect at the time and in the context of the collection of the personal data that processing for that purpose may take place. (…).”
The processing of your personal data described in this Privacy Notice is necessary (i) for the purposes of legitimate interests pursued by NBL in the frame of its fundamental rights to pursue an activity which is not overridden by your interests, fundamental rights and freedoms (Article 6.1.f of the GDPR) and, (ii) in some cases, necessary to comply with legal or regulatory obligations.
NBL considers none of the purposes described are prejudicial to You.
Moreover, while giving us your personal data and your resume or while sharing your personal data, for instance on professional networks such as LinkedIn, NBL has legitimate reasons to consider (i) You gave your consent to processing such personal data and (ii) You can reasonably expect such personal data to be used, and in particular by NBL to provide recruitment advisory, to assess your professional skills, to double check and confirm your references.
It is thus reasonable and legitimate to NBL to process your personal data in the frame of its business activities.
Personal data we collect and process
NBL collects and processes personal data You give us by personal contact (phone call, mail, email) or following direct contact made by us.
NBL collects and processes personal data from publicly available sources like professional networking websites (LinkedIn, other professional data bases).
The personal data NBL collects typically include:
- Identification data such as your name, civil/marital status, contact details, photograph, date of birth, gender, national origin, languages and other skills…
- Education background: qualification, diplomas, …
- Professional experience: employment history, professional contact details, compensation, …
- Contact details of the referees You provided NBL with
- Any other information included in your resume or obtained from publicly available sources (professional networking websites such as LinkedIn)
- Any additional information You decide to share with us and/or your referees, and any other source (universities, ) chooses to share with us.
NBL does not collect or process any personal data in the field of race, ethnicity, political opinions, religion or philosophical beliefs, health, sexual orientation, or trade unions membership.
How we share your personal data
We may share your personal data with the following types of third parties for the purposes described in this Privacy Notice:
- Companies, associations or institutions which awarded NBL a recruitment, assessment or coaching assignment
- NBL’s sister companies operating under the label “Global Board Advisors” (please refer to NBL’s website)
- Any competent law enforcement body, regulatory or government agency, court or other third party where we believe disclosure is necessary as a matter of applicable law or regulation; to exercise, establish, or defend our legal rights; or to protect your vital interests or those of any other person
- Third party service providers which perform functions on NBL’s behalf: (i) group companies for accounting purposes, (ii) IT service providers (IT security and data base supplier). These suppliers or third parties have reglementary, legal and contractual obligations to protect the confidentiality and security of your personal data. They access your personal data only to the necessary extent of their functions.
Retention of your personal data
Unless specified by any regulation, we will delete your personal data two years after our latest contact with You (written or verbal communication).
Should You give us your formal consent; we will retain your personal data for more than two years.
Personal data security
NBL takes appropriate technical and organisational measures to protect your personal data from loss, misuse, unauthorised access, disclosure, alteration and destruction. The measures NBL takes are designed to provide a level of security appropriate to the risk of processing your personal data.
Access to your personal data is strictly restricted to consultants and members of NBL’s personnel included in the selection and recruitment process.
Your data protection rights
In accordance with applicable data protection law and under certain conditions, You have the following data protection rights:
- You can access, correct, update or request deletion of your personal data
- You can ask us to restrict processing of your personal data
- You can object to processing of your personal data
- You can request portability of your personal data to You or another controller
- You can withdraw your consent when personal data processing is based on it.
You may contact us using the details below:
NB Lemercier & Associés
15, avenue de l’Observatoire
75006 Paris
Personal data we keep should be correct and accurate. Should any of it change, thank You for informing us.
Ultimately, You have the right to complain to the French data protection authority (la Commission Nationale de l’Informatique et des Libertés known as “CNIL”) about our collection and use of your personal data.
***