Last Updated: 21 May 2018
HEALTHCARE TECHNOLOGY INTERNATIONAL (H.T.I) takes the privacy and security of your information seriously.
H.T.I. is a global consulting firm dedicated to the Life Sciences Industry. We help companies to select and hire the talent they need to execute their strategy – we also provide assistance in terms of compensation & benefits as well as in Coaching & mentoring tasks.
Our Headquarters is located 20, rue Jacques Dulud – 92200 Neuilly sur Seine – France – registered RCS Nanterre – 41517270900024.
This Private Policy governs the manner in which H.T.I. collects, uses, maintains and disclosures information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR). This policy may be amended or updated from time to time to reflect changes in our practices with the respect to the Processing of Personal Data or changes in applicable law. We recommend you to read this Policy carefully and to regularly check this page to review any changes. We will of course notify you of any major changes.
It applies to all employees, workers, contractors, candidates and individuals at clients or potential clients of ours in respect of whom we hold personal data. This notice does not form part of any contract of employment, a contract to provide services or any other contract.
Processing your Personal Data
Collection of Personal Data: We may collect Personal Data about you, such as your name, address and contact details. We will comply with data protection law. This says that the personal information we hold about you must be:
– Used lawfully, fairly and in a transparent way and kept securely
– Relevant to the purposes we have told you about and limited only to those purposes.
– Accurate and kept up to date.
– Kept only as long as necessary for the purposes we have told you about
Examples of sources from which we may collect Personal Data include the following:
- We may obtain your Personal Data when you provide it to us (e.g., where you contact us via email or telephone, or by any other means).
- We may collect your Personal Data in the ordinary course of our relationship with you (e.g., if we offer to connect you with our Clients we may collect your Personal Data that are related to such Client opportunities, such as your CV
- We may share your Personal Data with other HTI’s office.
- We may collect Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible).
- We may receive your Personal Data from third parties who provide such data to us (e.g., past employers; referees; educational establishments; online CV services and databases; and law enforcement agencies).
- We may, with your prior express written consent, conduct background checks (including educational checks), in accordance with the protections provided by applicable law.
- We may collect or obtain Personal Data when you visit our website or use any features resources available or through our website. When you visit the website, your device and browser will automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to the website and other technical communications information), some of which may constitute Personal Data.
Creation of Personal Data: We may also create Personal Data about you, such as records of any interviews you attend. These Personal Data help us to conduct our operations and manage our workforce.
Personal Data you provide about others: In some circumstances, you may provide us with Personal Data about others. For example, you might act as a Source and provide comments on a Candidate or Participant. Whenever you provide any such Personal Data, we rely on you to ensure that you have a lawful basis for providing such Personal Data to us, and that you have complied with applicable law and with the terms of this Policy. If you are unable to do so, please refrain from providing such Personal Data to us.
Relevant Personal Data: The categories of Personal Data about you that we may Process include:
- Personal details: given name(s); preferred name; gender; date of birth / age; nationality; photograph; marital status; job title; employer entity; department; salary and compensation details; passport number (where applicable); visa number (where applicable); and work authorization number (where applicable).
- Contact details:</i >home address; work address; home telephone number; work telephone number; work mobile number; personal mobile telephone number; personal email address; work email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media profile details.
- Employment records:dates and details of current and former positions held; details of current and former employers; dates of employment; job titles; job locations; subject matter experience; and details of any employment disciplinary issues or incidents.
- Details of referees:details of referees you may provide, including the relationship that you may have with each such referee, and the duration for which you have known each such referee.
- Background checks and educational checks: details revealed by background checks conducted in accordance with applicable law and subject to your prior express written consent, including details of past employments, educational degrees, details of residence, credit reference information, and criminal records checks.
- Views and opinions: your views on candidates or participants, where applicable.
Lawful basis for Processing Personal Data: In Processing your Personal Data in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases:
- we have obtained your prior express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
- the Processing is necessary in connection with any contract that you may enter into with us;
- the Processing is required by applicable law;
- the Processing is necessary to protect the vital interests of any individual; or we have a legitimate interest in carrying out the Processing, which is not overridden by your interests, fundamental rights, or freedoms. Where we rely on this legal basis, our legitimate interests are our legitimate interest in the management and operation of our business; our legitimate interest in the promotion of our business; and
We do not seek to collect or otherwise Process your Sensitive Personal Data, except where:
- the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
- the Processing is necessary for the detection or prevention of crime;
- the Processing is necessary for the establishment, exercise or defence of legal rights; or
- we have, in accordance with applicable law, obtained your prior explicit consent before Processing your Sensitive Personal Data (as above, this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
The purposes for which we may Process Personal Data, subject to applicable law, include:
- Executive search and Recruitment activities on behalf of Clients: recruitment operations; advertising Client opportunities; providing services to our Clients; enabling Clients to understand which Candidates are interested in their opportunities; record-keeping; and performing background checks.
- Leadership consulting including Executive Assessments: providing leadership consulting services to Clients.
- Coaching and mentoring: providing coaching and mentoring services to you and our Clients.
- Provision of services to you: providing our Site and other services to you; attending meetings with you; attending telephone calls with you; and otherwise communicating with you in relation to those services.
- Our website: operating and managing our Site; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our Site.
- Newsletters and other marketing communications: subject always to compliance with applicable law, communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and possible opportunities in which you may be interested.
- Communications and IT operations: management of our communications systems; operation of IT security; and IT security audits.
- Future planning: succession and organizational planning, including budgeting.
Disclosure of Personal Data to third parties
We may also share aggregate demographic information with our Clients, trusted affiliates and advertisers for the purposes outlined in this Policy. While we make all reasonable efforts to ensure that such information is anonymized, it is possible that small amounts of your Personal Data may be included.
In addition, we may disclose your Personal Data to:
- legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- our Clients, for the purposes of providing services to those Clients, in accordance with the provisions of this Policy;
- accountants, auditors, lawyers and other outside professional advisors to our company, subject to binding contractual obligations of confidentiality;
- third party Processors (such as providers of background checking services), located anywhere in the world, subject to the requirements noted below hereafter.
- any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;
- any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security;
- any relevant third party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
- our website may use third party plugins or content (e.g., social media plugins). If you choose to interact with any such plugins or content, your Personal Data may be shared with the relevant third party.
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: only Process the Personal Data in accordance with our prior written instructions; and use appropriate measures to protect the confidentiality and security of the Personal Data.
International transfer of Personal Data
Because of the international nature of our business, HTI may need to transfer your Personal Data to each other branches of HTI, and to third parties as noted above, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. In particular, your Personal Data may be disclosed by one HTI office to another HTI office, to the extent appropriate, in connection with any Client opportunities in respect of which you are a Candidate, or any Leadership Assessment in which you are a Participant.
We may transfer the personal information we collect about you outside the EU like USA, Canada, and others. There might not be an adequacy decision by the European Commission in respect of those countries. This means that the country’s domestic law or international commitments have not been determined by the European Commission to provide an adequate level of protection for your personal information.
However, to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU law on data protection: organizations to which your personal data is sent outside of the EU have a legally binding contract with us, governed by French Law, requiring them to comply with French legislation relating to data protection; all personal data is kept strictly confidential and can only be disclosed as required by the contract; and only those staff who need to have access to personal data for the performance of their contractual obligations are permitted to have access to it.
Security & data retention
We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
You are responsible for the ensuring that any Personal Data that you send to us are sent securely.
We take every reasonable step to ensure that:
- your Personal Data that we Process are accurate and, where necessary, kept up to date; and
- any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without undue delay.
From time to time we may ask you to confirm the accuracy of your Personal Data.
We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:
During the periods noted above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods mentioned above, each to the extent applicable, have concluded, we will either:
- permanently delete or destroy the relevant Personal Data;
- Anonymized the relevant Personal Data.
Your legal rights
Subject to applicable law, you may have a number of rights regarding the Processing of your Personal Data, including:
- the right to request access to, or copies of, your Personal Data that we Process or control;
- the right to request rectification of any inaccuracies in your Personal Data;
- the right to request, on legitimate grounds:
- Erasure of your Personal Data that we Process or control; or
- restriction of Processing of your Personal Data that we Process or control;
- the right to object, on legitimate grounds, to the Processing of your Personal Data;
- the right to have your Personal Data transferred to another Controller, to the extent applicable;
- where we Process your Personal Data on the basis of your consent, the right to withdraw that consent; and
- the right to make complaints regarding the Processing of your Personal Data with a Data Protection Authority.
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details here below.
If, and to the extent that, you are a Candidate or Participant, we rely on you to provide us with complete and accurate Personal Data about you, so that we can provide appropriate services to you and to our Clients.
If, and to the extent that, you are a Source, we rely on you to ensure that you are lawfully able to disclose Personal Data to us, as set out in this Policy.
Data Protection Officer
If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data by HTI, please contact firstname.lastname@example.org