Capstone Professional Services’ commitment to Privacy
Capstone Professional Services respects your privacy and is committed to protecting your personal data. We will fully comply with our obligations under the General Data Protection Regulations which came into force on the 25th May 2018.
Purpose of this privacy notice
This privacy notice will inform you as to how we look after your personal data collected when you visit our website or have otherwise provided to us offline in the course of our dealings with you. It also tells you about your privacy rights and how the law protects you.
Neither this website nor our business operations generally are intended for children and we do not knowingly collect data relating to children.
You must read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
For those that are employed by us or engaged by us under a consultancy agreement, we have an additional privacy notice which is particular to the personal data we collect and process concerning such individuals. We will provide that privacy notice to those impacted individuals at appropriate times during our recruitment or engagement process. If you wish to access a copy of this specific privacy notice, please contact us at
Capstone Professional Services is the controller and responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy notice), although we do also operate fluidly between the group of companies which include ‘Capstone Property Recruitment’ and ‘Capstone Property Recruitment (Interim)’.
Our full details are:
Full name of legal entity: Capstone Professional Services Ltd
Postal address: 1st Floor, Northumberland House, 155-157 Great Portland Street, London W1W 6QP
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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 notice and your duty to inform us of changes
Our website does not generally but 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 notice of every website you visit.
1. 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 follows:
CONSULTING AND OTHER REAL ESTATE AND CONSTRUCTION SERVICES (INCLUDING CLIENT REGISTRATION FOR RECRUITMENT OR SEARCH SERVICES):
Identity Data includes first name, maiden name, last name, title, possibly date of birth and gender.
Contact Data includes billing address, work address, email address and telephone numbers.
Financial Data includes invoice details and any other relevant financial information based on the nature of the services we are providing to you.
Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
RECRUITMENT AND SEARCH SERVICES (CANDIDATES):
Identity and Contact Data, as above
Work Experience Data includes your competences, skills, experience and education, e.g. your CV or resume, previous employments, educational details and qualifications, third party references.
GENERAL DATA COLLECTION:
Marketing and Communications Data (if applicable) includes any 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 may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
We do not 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 unless it is explicitly required as part of a recruitment process or when we are proposing to place a consultant into a work placement. We have a separate privacy notice concerning criminal conviction searches which will be provided to you at the relevant time, although a copy can be provided on request.
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.
2. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
You may give us your Identity, Contact, Marketing Data, Financial Data or, if appropriate, Work Experience Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes the personal data you provide when you:
seek our consulting or other real estate and construction services;
ask us to find recruitment opportunities for you;
request marketing to be sent to you; or
give us some feedback.
Automated technologies or interactions.
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Client Data – clients may provide us with certain personal data to us in connection with the services we are providing to them, whether that be real estate consulting services or recruitment services.
Referee Data – referees may be provided by third parties, either provided by you as part of your recruitment submission or from third party referrals.
Third-Party Market Research Data – as part of our search process we may from time to time use third party agencies to help with our search processes.
Search engines, social media and online networking sites such as LinkedIn.
Identity and Contact Data from publicly availably sources such as Companies House and credit agencies.
Third-party sites to validate your criminal record status as required by our clients.
3. 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 we need to perform the contract we are about to enter into or have entered into with you.
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 comply with a legal or regulatory obligation.
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). This is particularly the case in relation to our recruitment business where we need to not only share data but also to retain certain historical data in order to assist our clients and our candidates in an effective recruitment process. 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 at firstname.lastname@example.org
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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
To the extent that we operate any marketing programmes, we will always seek your explicit consent. Any communication will always permit you to unsubscribe from further communications or you can do so at any time by contacting us.
We do not currently share your personal data with any company outside the Capstone group of companies for marketing purposes. If we were to do, we would get your explicit consent before doing so.
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.
4. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes outlined in paragraph 3 above.
Internal Third Parties
Recruitment - candidate personal information will only be shared with people who operate within our recruitment business, although we may disclose your basic information to other Partners who are involved in our Consulting business if we feel that may be of use in a recruitment or work opportunity.
Consulting - any personal data will be available to the Partners of Capstone Professional Services as well as those that are involved in particular activities such as billing.
External Third Parties
Recruitment - clients or prospective employers, if we are submitting your personal data as part of a recruitment process. We will always seek your consent prior to submitting your personal data.
Consulting - we may provide personal data to those third parties which are necessary as part of our consulting services.
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 notice.
In all cases, we will ensure that there are appropriate limits or controls on the data that is transferred and that it is appropriate given the nature of our appointment.
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.
5. INTERNATIONAL TRANSFERS
We do not usually transfer your personal data outside the European Economic Area (EEA).
However, we do operate in certain countries outside of the EEA and would be willing to discuss with our clients operating in other jurisdictions should they have a need for our services there. If that is the case, we may need to transfer your data outside the European Economic Area (EEA).
In such event, we will ensure that your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules". For further details, see European Commission: Binding corporate rules.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. 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.
7. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements. In relation to our recruitment business, we will also consider to what extent we have been active with you as part of our recruitment services (such as discussing roles with you or placing you into interviews and/or when we last placed you into a role).
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.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data
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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
If you wish to exercise any of the rights set out above, please contact us.
No fee 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 may 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 may 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.