Welcome to the Armstrong Craven privacy policy.

Armstrong Craven is a global leader in the provision of research-based talent solutions. We work with some of the world’s most influential and respected businesses, who are often undergoing transformational change, and need to identify and recruit high demand or specialised talent. We provide specialist talent mapping, talent pipelining and insights to help our clients ensure they can attract, hire and retain the scarce and senior talent they need on a global basis. In doing so, we respect your privacy and are committed to protecting your personal data.  

This privacy policy will inform you as to how we look after your personal data when you visit our portal or website (regardless of where you visit them from) and tell you about your privacy rights and how the law protects you. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1.    Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Armstrong Craven collects and processes your personal data through your use of this website or our portal, including any data you may provide through the website or our portal when you use our services, sign up to our newsletter, or contact us. 

This website and our portal are not intended for children and we do not knowingly collect data relating to children. 

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. 

Controller

Armstrong Craven is part of a group called WhiteCrow Research (https://whitecrowresearch.com). Armstrong Craven as a brand is made up of different legal entities: Armstrong Craven a division of Colvill Banks Limited; Armstrong Craven Pte. Ltd.; Armstrong Craven Hungary Kft; and Armstrong Craven Inc. This privacy policy is issued on behalf of the Armstrong Craven brand so when we mention "Armstrong Craven", "we", "us" or "our" in this privacy policy, we are referring to the relevant part of the Armstrong Craven brand responsible for processing your data. We will let you know which entity will be the controller for your data when you use one of our services. WhiteCrow Research is the controller and responsible for this website. 

We have appointed Data Protection Leads who are responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Protection Leads using the details set out below. 

Colvill Banks Limited is registered as a Data Controller with the ICO under ICO registration 00013049952.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Leads in the following ways: 

Full name of legal entity: Armstrong Craven, a trading division of Colvill Banks Limited 

Email address: GDPR@armstrongcraven.com 

Postal address: Fourth Floor Suite, 3 Barrington Road, Altrincham, Cheshire, United Kingdom, WA14 1GY 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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. 

Changes to the privacy policy and your duty to inform us of changes 

We keep our privacy policy under regular review. This version was last updated in April 2024. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
This 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.

2.    The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, as well as data that is typically held in a curriculum vitae (CV) such as employment history, qualifications, skills, languages and interests. It may also include, but is not limited to; nationality, compensation details, reporting lines, team sizes, a record of our contact history with you and comments, and views or references from third parties. We recommend that you do not provide information which may be deemed sensitive on your CV as we will retain any documents that you have provided in line with our retention schedule.
• Contact Data includes address, email address and telephone numbers.
• Financial Data includes bank account details.
• Transaction Data includes details about payments to and from you and other details of  services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, 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 this website. 
• Profile Data includes your username and password, your use of our services, your interests, preferences, feedback and survey responses.  
• Usage Data includes information about how you use our website and services. 
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not normally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, if relevant to a specific assignment and subject to your explicit consent, we may process Special Categories of Personal Data relating to you.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 

3.    How is your personal data collected?

We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• enquire about or use our services;
• create an account on our website;
• subscribe to our service or publications; 
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us. 

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: 

• Technical Data from the following parties:
  • (a)    analytics providers such as Google based inside and outside the UK; 
  • (b)    third party sources such Egnyte, based in the US;
• Contact, Financial and Transaction Data from your bank;
• Identity and Contact Data from data brokers or aggregators such as LinkedIn, HireEZ, SignalHire and Indeed based inside and outside the UK.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

4.    How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where we need to comply with a legal obligation.

Please see the definition of lawful basis in the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before making representations about your interest or availability for any role, or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Marketing 
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established your My Profile page in our AC Connect portal where you can view and make certain decisions about your personal data use.

Promotional offers from us 
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing 
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time. 
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the use of our service, service experience or other interactions.

Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.armstrongcraven.com/cookie-policy/

Change of purpose 
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Applicants
If you have applied for a role to work at Armstrong Craven, information you provide and information that we gather through the interview and assessment process will be used to assess your suitability for opportunities with us. 

You may be asked to provide equal opportunities information. This is not mandatory information – and it will not affect your application if you do not provide this. This information will be anonymised and will only be used to produce and monitor equal opportunities statistics.

If you are unsuccessful following assessment for the position you have applied for, or decided to withdraw from the process, we may ask if you would like your details to be retained in our talent pool for a period of up to two years so we can contact you should any suitable opportunities arise.

5.    Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties as set out in the Glossary. 
• External Third Parties as set out in the Glossary.
• Specific third parties such as where we have retained them to provide services that you or our clients have requested, such as recruitment services, referencing, qualification and criminal reference checking services (as required and subject to consent), verification of the details you have provided from third party sources, psychometric evaluations or skills tests.  We may also share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems and function co-ordinators. These third parties are also required to comply with the obligations of the GDPR and will have similar and equally stringent undertakings of privacy and confidentiality.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

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.

6.    International transfers

We share your personal data within the Armstrong Craven Group. This will involve transferring your data outside the UK.

Whenever we transfer your personal data out of the UK, 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.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 
• Where you have given explicit consent to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and appropriate safeguards.
• Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK. 

7.    Data security

We have put in place 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 put in place 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.

8.    Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see the section on your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

9.    Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary section below to find out more about these rights: 

• 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.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us. No fee is usually required.

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.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

10.    Glossary

LAWFUL BASIS
 Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties
Other companies in the Armstrong Craven Group acting as joint controllers or processors and who are based in the US, Singapore, Switzerland, Australia, Hungary, South Africa and Sweden. who need the data for operational and business purposes. 

External Third Parties

• Service providers acting as processors based in the UK USA and India who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the US, Singapore, Switzerland, Australia, Hungary and Sweden who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Background checking services such as Experian, based in side and outside the UK to check credit history and (where appropriate) criminal records. Such background checks will only be made with your consent. 

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.