Who we are and what we do

Bold Horizon International Limited (“Bold Horizon”) is a leadership advisory and executive search practice. We collect, use and store personal data in order to provide those services.

We are the data controller for the personal data described in this policy. We are registered in England and Wales, company number 16498844, with our registered office at 3 The Depository, Rock Villa Road, Royal Tunbridge Wells TN1 1HA. You can contact us at david@boldhorizon.co.

Personal information is stored, processed and sometimes transferred at various stages of an assignment, both during and after it is completed.

Purpose of this policy

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, is processed. It is written to meet our obligations under the UK General Data Protection Regulation and the Data Protection Act 2018.

The data we collect about you

We use your personal data to assess your suitability for senior appointments we have been engaged to fill. Initially we collect basic information: your name, contact details and current role. Once we have your agreement, we may collect and share further information, including your career history or CV, remuneration details and references.

Depending on the assignment, we may also collect information about your nationality and your right to work, and information arising from background screening where a client requires it. Where that screening involves information about criminal convictions or offences, we will tell you before it is carried out and will only process it where we have a lawful basis to do so.

Where we collect your personal data from

• From you directly.

• Publicly available sources.

• LinkedIn and other professional networking sites.

• Corporate websites.

• Referrals and references from people who know your work.

Where we obtain your data from a source other than you, we will tell you within a reasonable period and, in any event, before or at the point we first contact you.

Why we collect your personal data, and our lawful basis

We collect personal data to match you to senior opportunities we have been retained to work on, to assess suitability for those roles, to build an understanding of the market, and to meet our obligations to our clients.

For most of this processing, our lawful basis is legitimate interests: operating an executive search practice, which cannot function without holding information about the people it may introduce to clients.

We have considered your interests and rights and have concluded that this processing does not override them. We also rely on:

• Your consent, where we ask for it specifically.

• The performance of a contract, where one exists between us.

• Compliance with a legal obligation.

• The establishment, exercise or defence of legal claims.

Where we rely on consent, you can withdraw it at any time by contacting us. Withdrawing consent does not affect processing carried out before you withdrew it.

How long we keep your data

We keep your personal data only for as long as we need it for the purposes set out above, or for as long as the law requires. In deciding how long that is, we consider the nature of the data, whether an assignment is still live, whether you may wish to be considered for future roles, and any legal or regulatory retention periods that apply. Data we no longer need is deleted.

Who we share your personal data with

We share your personal data with clients who have engaged us on an assignment that may be relevant to you, and only that information you have agreed to can be shared. We do not sell personal data, and we do not share it for marketing purposes.

Where an assignment involves psychometric assessment, we may share relevant data with an independent occupational psychologist instructed for that assignment. We will tell you before this happens.

Transfers outside the United Kingdom

We work with clients across Europe, so with your knowledge, your personal data may be transferred outside the United Kingdom. Where we do so, we rely on one of the following:

• The country has been recognised as providing an adequate level of protection under UK adequacy regulations.

• Appropriate safeguards are in place, such as the International Data Transfer Agreement or the UK Addendum to the European Commission's standard contractual clauses.

• You have given explicit consent to the transfer after being told of the possible risks.

• The transfer is necessary for one of the other reasons permitted by the UK GDPR, including the performance of a contract, the establishment, exercise or defence of legal claims, or reasons of substantial public interest.

Your rights

You have the right to:

• Request access to your personal data, commonly known as a subject access request.

• Request correction of personal data that is incomplete or inaccurate.

• Request erasure of your personal data where there is no good reason for us to continue processing it.

• Object to processing where we rely on legitimate interests and there is something about your situation that makes you want to object. You may object to direct marketing at any time.

• Request restriction of processing, for example while its accuracy is being established.

• Request the transfer of your personal data to another party.

• Withdraw your consent, where our processing relies on it.

To exercise any of these rights, contact us at david@boldhorizon.co. We will respond within one month. There is normally no charge.

Complaints

If you are unhappy with how we have handled your personal data, please tell us first so that we can put it right. You also have the right to complain to the Information Commissioner's Office, the UK supervisory authority for data protection, at ico.org.uk or on 0303 123 1113.

Updates to this policy

We keep this policy under review and will update it to reflect changes in data protection law or in how we work. This version was published on [date].

How to contact us

Questions, comments and requests about this policy should be sent to david@boldhorizon.co, or by post to Bold Horizon International Limited, 3 The Depository, Rock Villa Road, Royal Tunbridge Wells TN1 1HA.