Respect. Confidentiality. Trust.

As a provider of Executive Search, Leadership and Board Advisory Services, Amrop’s business has always been based on trust, confidentiality and respect for privacy.

We recognize that our role in protecting personal data is critical – on behalf of our clients, our candidates and all members of the Amrop Partnership. We are committed to ensuring that all personal data shared and processed within Amrop is protected, private and secure, thus also providing a framework for compliance with General Data Protection Regulation (EU) 2016/679 (GDPR) and other data protection legislation.

Accountability

Amrop adheres to the principles and requirements of data protection and relevant national or regional legislation, including those of the European Economic Area (EEA) where the GDPR applies. 

Executive Search Baltics SIA

PRIVACY POLICY

1. This Policy

This Policy is provided by Executive Search Baltics OÜ (“Executive Search Baltics OÜ”, “we” or “us”), and is addressed to individuals outside our organisation with whom we interact, including (but not limited to) Candidates, Participants and Sources (together, “you”). Defined terms used in this Policy are explained in Section ) below.

For the purposes of this Policy, Executive Search Baltics OÜ is the Data Controller. Contact details are provided in Section ) below.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

2. Processing your Personal Data

Collection of Personal Data: We may collect Personal Data about you, such as your name, address and contact details. 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 résumé).

• We may receive your Personal Data from other members of the Amrop network of firms, to the extent that those members provide it to us.

• 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 or available to one of our employees).

• We may receive your Personal Data from third parties who provide it to us (e.g., past employers; referees; and law enforcement agencies).

• We may, with your prior express written consent, conduct background checks, in accordance with the protections provided by applicable law.

Creation of Personal Data: We may also create Personal Data about you, such as records of any interviews you attend. This Personal Data helps us to conduct our operations and manage our legitimate business interests.

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 the Personal Data of third parties to us.

Relevant Personal Data: The categories of Personal Data about you that we may Process include:

Purpose	Types	Lawful basis
Gather referrals from you about a candidate	Name	Consent or Legitimate interest of our client to recruit employees, if you have not been involved in our placement projects
	Surname
	Job title
	Contact information
Marketing: Information about assessments, assignments or leadership consulting services	Name	Consent
	Surname
	Contact information
Considering you as a candidate for clients of SIA Executive Search Baltics and storing your profile in our database	Curriculum Vitae	Legitimate interest of our client to recruit employees in the market research phase. We shall obtain your consent once we would like to invite you to an interview or share your personal data with a client.
	Name
	Phone number
	E-mail address
	Educational history
	Employment history
	Degree(s) and other qualifications
	Languages and other skills
	Nationality
	Current job title and role / function
	Salary and compensation data (including non-salary benefits, bonuses and incentives and other financial information)
	Annual leave information
	Retirement and pensions information
	Performance reviews and disciplinary information
	Views and opinions regarding the suitability of the Candidate for a particular role within a client’s organisation
	Social media presence and activity
	Training and development,
	Compliance with applicable policies, procedures, standards and guidelines and related investigations

Processing your Sensitive Personal Data: 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 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).

3. Disclosure of Personal Data to third parties

We may disclose your Personal Data to other members of the Amrop Partnership network, for legitimate business purposes (including providing services to you and operating our Sites), in accordance with applicable law.

In addition, we may disclose your Personal Data to:

• our Clients, for the purposes of providing services to those Clients, in accordance with the provisions of this Policy;

• third party Processors (such as providers of background checking services), located anywhere in the world, subject to the requirements noted below in this Section (C).

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data or (iii) have a statutory obligation of confidentiality.

4. International transfer of Personal Data

Because of the international nature of our business, we may need to transfer your Personal Data to other entities within the Amrop Partnership network, and to third parties as noted in Section (C) 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 to other members of the Amrop Partnership network, 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.

Where we transfer your Personal Data to other countries, we do so on the basis of Standard Contractual Clauses.

5. Data Security

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.

6. Data Accuracy

Your Personal Data that we Process will be kept accurate and, where necessary, kept up to date. 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 delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

7. Data Minimisation

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably required in connection with the purposes set out in this Policy.

8. Data Retention

We will keep copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law permits or requires a longer retention period.

The criteria for determining the duration for which we will keep your Personal data are as follows: we will retain your Personal Data for as long as we have your permission to contact you. Should you wish to withdraw that permission, you may do so using the contact details provided in Section ) below.

9. 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 lodge complaints regarding the Processing of your Personal Data with a Data Protection Authority – Latvian State Data Inspectorate (Datu Valsts Inspekcija).

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 provided in Section ) below.

10. Your obligations

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.

11. Contact details

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 Executive Search Baltics OÜ, please contact us at e-mail tallinn@amrop.com or phone +372 66 77 800.

12. Definitions

• ‘Candidate’ means a candidate, or potential candidate, for a position with a Client.

• ‘Client’ means a client of Executive Search Baltics SIA, or any other member of the Amrop network.

• ‘Controller’ means the entity that decides how and why Personal Data is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

• ‘Data Protection Authority’ means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

• ‘Leadership Assessment’ means any leadership assessment service (including, but not limited to, any management audit, leadership consulting service, coaching, team development, team effectiveness analysis, or succession planning) provided by the Controller to the Client for the purposes of assessing the leadership potential of its own Personnel or other individuals selected by the Client.

• ‘Participant’ means any individual participating in a Leadership Assessment.

• ‘Personal Data’ means information that is about any individual, or from which any individual is identifiable. Examples of Personal Data that we may Process are provided in Section (B) above.

• ‘Personnel’ means any current, former or prospective employee, consultant, temporary worker, intern, other non-permanent employee, contractor, secondee or other personnel.

• ‘Process’, ‘Processing’ or ‘Processed’ means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

• ‘Processor’ means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

• ‘Sensitive Personal Data’ means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.

• ‘Source’ means any person that provides any view or opinion regarding the qualities of any Candidate or Participant, for any purpose, including but not limited to the suitability of a Candidate or Participant for a particular role.