Privacy Policy | KT Consulting

Who we are and how do we process your personal data

KT Executive Search AG, represented by Kirill Tsybulevsky (referred to as "KT"), is committed to protecting the privacy and personal data of our candidates, clients, and users of our website. We ensure that the personal data we collect is used solely for the purposes outlined in this Privacy Policy and in compliance with the Swiss Federal Act on Data Protection (FADP) and applicable regulations. KT aims to be transparent under the EU General Data Protection Regulation 2016/679 ("GDPR") and national laws that may be applicable.

Scope

Protecting your personal data is our priority. This privacy policy explains how the Companies process and protect personal data about:

Candidates who register with us for roles that we are managing for other employers and for roles within the Companies, or through our website, job boards, social media sites or other sources;
Prospective candidates;
Prospective clients;
Business contacts at our clients and suppliers;
Users of our websites.

Collectively referred to as "you" or "your." This policy outlines your privacy rights, including your right to object to our processing of your personal data. Please see the “How to Contact Us” section of this policy.

Personal Data We Collect

Candidates

When you register as a candidate, we collect personal data such as:

Name and contact details;
Information from your CV.

Where permitted by law, we may also collect information relating to:

Health information (if permitted by law, for example, disability information for reasonable work adjustment purposes);
Diversity information (including race, ethnic origin, sexual orientation and religion for equal opportunity monitoring);
Details of unspent criminal convictions (if required by a client or by us, if you apply for a role with us).

The KT entity acting as Data Controller of your data in this case will be the one managing the process to which you have applied.

We also gather data from interactions with our website, when you click on links in emails we send to you, open or forward them, or sign up to receive job alerts or other contents from us, we also collect personal data from those interactions. We also obtain personal data about you from third parties, including:

Referees - when you are offered a job;
Former employers - to confirm dates of employment;
Educational institutions - to check your academic qualifications;
Credit reference agencies - if we need to check your financial standing;
Publicly available sources such as LinkedIn and social media sites to enhance the information we hold about you, in order to help us find more suitable roles for you;
Clients to whom we have provided your CV and who have engaged with you as part of a job application or who have given feedback on your CV.

Prospective Candidates

We collect personal data about you including your name and contact details and professional biographical details obtained from publicly available sources such as LinkedIn, CV websites and social media websites, so that we can contact you if we think you may be interested in our work finding services at a future date. We may also obtain your personal data through another candidate or an employer who recommends you as a contact. The KT entity that will act as Data Controller of your data in this case will be the entity to which the consultant who has identified you as a prospective candidate belongs.

Prospective Clients

We collect contact details and position-related data to establish commercial relationships with your company. The KT entity that will act as Data Controller of your data in this case will be the entity to which the consultant who has identified you as a potential client belongs.

Users of Our Website or Apps

We collect your IP address and device data to enhance your online experience and track website engagement through cookies. If you contact us, we will also collect information about your enquiry. We use cookies and similar technologies to collect a lot of this information and our cookie policy tells you more about this. The KT entity acting as Data Controller in this case shall be the entity to which the website belongs, whose details can be found in the website's legal notice or the list attached at the beginning of this Privacy Policy.

Clients

We collect your name, job title, contact details, and any feedback you provide about our services. We also process personal data about what communications we have had with you, including whether you have opened or forwarded any emails, newsletters or other content we have sent to you. We also process feedback that you provide about our candidates. The KT entity that will act as Data Controller in this case will be the entity that is the counterparty in the contract we sign with you or with the company you represent. If you provide information to us about a candidate (for example, if you confirm a candidate has worked with you or if you provide a reference), then we will obtain your details from the candidate and we will keep a record of the personal data that you provide to us about that candidate. We process personal data about you from public domain sources such as LinkedIn and social networking sites, or because you were a delegate at one of our events or at an event where the event organiser is permitted to share delegate details with us.

Suppliers

We typically collect your name and contact details as a business contact for your organisation. The KT entity that will act as Data Controller in this case will be the entity that is the counterparty in the contract we sign with you or with the company you represent.

Providing your personal data

In some cases, it will be necessary for you to provide personal data to us. If you don’t provide us with the personal data we ask for, we may not be able to provide you with our services.

How we use your personal data

Candidates

We use your personal data to:

Provide work finding services;
Communicate and assist with job applications;
Enable you to upload your CV and apply for jobs;
Personalise your experience by creating a candidate profile;
Monitor equality and diversity;
Provide you with interviewing and salary advice;
Send you direct marketing communications (with your consent) about job opportunities, industry reports and insights, events, promotions and competitions, and other content in accordance with your marketing choices;
We also run targeted and relevant banner advertising on our website and within your social networks to present you and people like you with jobs and content that we believe will be of interest. We target these ads based on your previous interactions with our website, emails and through your engagements with our consultants. Your interaction with our ads may be used to measure the effectiveness of our ad campaigns and to improve our marketing strategy. This processing is carried out via Cookies and only if you have previously provided consent.

Prospective Candidates and Clients

We use your data to contact you to determine if you may be interested in our services and how we can assist you.

Users of Our Website or Apps

We may use your data to enhance and personalise your online experience and personalise advertising you receive from us.

Clients

We use your data to maintain our business relationship, communicate effectively, and fulfill contractual obligations. This includes:

Providing recruitment services to you;
Communicating with you;
Getting feedback from you on our services through client satisfaction surveys, in order to improve our services and to develop new services;
Maintaining our business relationship with you;
Answering your enquiries when you contact us;
Fulfilling contractual obligations to you;
Establishing, exercising or defending legal claims;
Direct marketing purposes.

Suppliers

We use your personal data:

to communicate with you;
to maintain our business relationship with you;
to answer your enquiries when you contact us;
to fulfil contractual obligations to you;
to establish, exercise or defend legal claims;
Direct marketing purposes.

You can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us. We have also established a marketing preference centre where you can view and make decisions about your marketing preferences and opt out of receiving marketing from us at any time.

Legal Grounds for Processing Your Personal Data

Under Swiss data protection regulations, we rely on the following legal grounds to process your personal data:

1. Performing a Contract: We process your personal data to fulfill our contractual obligations, such as providing recruitment services to clients and managing job applications for candidates. This includes taking necessary steps to enter into a contract with prospective clients or candidates.

2. Compliance with Legal Obligations: We may process your personal data to comply with applicable legal or regulatory obligations, including employment laws and data protection regulations.

3. Legitimate Interests: We process your personal data based on our legitimate interests or those of a third party. This includes:

- Responding to your requests and inquiries, which helps maintain effective communication with clients and candidates.

- Optimising the performance of our website and enhancing user experience.

- Contacting prospective clients to establish commercial relationships (the legitimate interest of KT is to maintain relations of any kind with the company where the contact person works).

- Informing you about our services, job opportunities, industry insights, events, promotions, competitions and surveys to assess client satisfaction (the legitimate interest of KT is to inform clients and candidates about similar services and products).

We have conducted a legitimate interest assessment to ensure our interests do not override your rights and freedoms. You can request this assessment using the contact details provided below.

4. **Consent**: In certain circumstances, we will seek your explicit consent to process your personal data. For example, if you register for a job, we may offer you the option to receive alerts for similar job opportunities. You have the right to withdraw your consent at any time. Please contact us if you wish to withdraw your consent.

Sharing Your Personal Data

We may share your personal data with or grant access to it to other companies within KT (in the European Economic Area (EEA)), both within and outside of Switzerland, in accordance with applicable regulations for international data transfers. If you would like a copy of the Standard Contractual Clauses (SCCs) used for these transfers, please contact us.

The purposes for sharing your personal data within KT include:

- Providing essential centralised services, such as IT and commercial support, where these entities process your data as data processors under the instruction of your data controller.

- Managing global, regional, or senior executive positions, or the development of key accounts, that require cooperation among various KT companies.

- Handling positions that may be fulfilled remotely.

The applicable legal bases for these processing activities are the performance of contracts with clients and candidates, or actions necessary to enter into a contract, along with our legitimate KT interests in delivering services efficiently.

If you register as a candidate in a country different from where you initially joined KT, a unique record will be created for you to enhance data accuracy and avoid duplication. For these purposes, the KT companies involved will share your personal information as independent data controllers.

Third Parties

For candidates, we share your personal data with clients who have job vacancies you may be interested in. The legal basis for this sharing includes the performance of contracts with clients and candidates and our legitimate interests in providing candidate information and services.

We may also share your personal data, including special category data where permitted by law, with third-party service providers who perform functions on our behalf, such as:

Conducting employment reference and qualification checks;
Carrying out criminal conviction checks as required;
Verifying details from third-party sources;
Conducting psychometric evaluations or skills tests;
Hosting personal data and providing data analytics;
Providing professional advice to us;
Administering surveys or competitions on our behalf;
Carrying out testing and development work on our business technology systems;
Assisting with communication, providing research and mailing house or other direct marketing services.

We contractually require third-party service providers to adhere to strict confidentiality and data protection standards. If we need to send personal data outside of the EEA, we will ensure that adequate safeguards are in place, such as using the Model Clauses.

Other Disclosures

We may also disclose your personal data:

If legally required to do so;
To law enforcement agencies, regulators, or other government officials;
To new business owners and their advisers in the event of a reorganisation, merger, sale, joint venture, assignment, or other transfer of our business.

Keeping Your Personal Data Secure

We have implemented and maintain appropriate technical and organisational measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Access to personal data is limited to authorised personnel and third-party providers on a need-to-know basis, and these employees and service providers are contractually obliged to treat this information as confidential.

Data Retention

We retain your personal data as long as necessary to fulfill the purposes for which it was collected, which may be an ongoing purpose, including compliance with legal obligations. For example, if you’re a candidate, we will retain your personal data for the duration of our business relationship with you and beyond, as we often support candidates with job placements over many years and potentially throughout their careers.

We keep some personal data for longer than others. To determine the appropriate retention period for personal data, we consider factors such as the purposes for which we process your personal data, including any legal, regulatory, accounting and reporting obligations, the nature and amount of personal data that we hold about you, and the potential risk of harm to you from unauthorised use or disclosure of your personal data.

Where we process your personal data for direct marketing purposes, we will do so until you ask us to stop, and for a short period after this (to allow us to implement your request). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely, so that we can respect your request.

Your Rights

You have several rights under EU data protection laws. These rights include the right to:

Ask us for a copy of your personal data;
Correct, delete or restrict processing of your personal data;
Obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format;
Ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process your personal data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example, if complying with your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests for keeping. We will inform you of any relevant exemptions we are relying on when we respond to your request.

Cookie Policy

We use cookies and similar technologies to enhance your experience on our website. For more details, please refer to our Cookie Policy.

How to Contact Us

To exercise your rights, or to withdraw your consent to processing, or to unsubscribe from receiving marketing communications from us, or if you have any questions about our privacy policy and about our processing of your personal data, you can:

write to us at: kirill@kt-consulting.ch

Questions and Complaints

If you have concerns or wish to make a complaint, you can email us at kirill@kt-consulting.ch. You also have the right to lodge a complaint with the relevant supervisory authority. If you have unresolved concerns, or believe that a personal data breach happened, you have the right to complain to your competent supervisory authority. A list of relevant authorities in the EEA can be accessed here.

Changes to Our Privacy Policy

We may update this Privacy Policy from time to time. If we do so, we will post updates on this site.This Privacy Policy version is in force since May 2024.