Annette Cove Associates have always been acutely aware of the sensitive nature of personal data and client confidentiality – whether that’s a new instruction for a major role, or a simple candidate email address. For us, GDPR is just the latest version of what we have always taken as read, but for the record, this is our current statement in respect to these new regulations.
1. Who and what we are:
Annette Cove Associates Limited is one of the UK's most highly respected search and selection agencies. We specialise in a wide range of recruitment services within the footwear and accessories sector, and partner with some of the best-known names in the industry.
Our mission is to secure premium talent for our clients by identifying common values, matching essential competencies and managing multiple expectations for long term mutual client and candidate satisfaction. The key to success for both parties is the intelligent and sensitive management of data.

2. The purpose of this privacy notice:
We totally respect the privacy of both prospective candidates and our clients, and are committed to protecting personal data wherever we operate in the world. This privacy notice will inform you as to how and what data we collect, how and why we use your data, how we share, retain and secure your personal data and finally, your rights and how the law protects you.
In order to operate and discharge our obligations to our clients, we collect data/information from both prospective candidates and client companies under three categories:
• Contact details
• Personal information
• Employment history

3. Our data controller:
Annette Cove Associates Limited is the controller and responsible for your personal data (collectively referred to as “the Company”, “we”, “us” or “our” in this privacy notice).The Company is the controller and is responsible for this website.
Should you need to contact us about anything contained in this statement, our contact details are as follows:
Full name of legal entity: Annette Cove Associates Limited
Name or title of the Data Privacy Manager: Annette Cove
Address: 8 Jury Street, Warwick CV34 4EW.

4. What data we collect:
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 including but not restricted to:
• Contact details: includes names, locations and basic contact information.
• Personal information: This data will vary for individual cases and projects in order to develop a sufficiently rich picture of each candidate’s background and suitability for any given opportunity.
Please note that the European Commission says that personal data relating to an individual, whether it relates to his or her private, professional or public life. It can be anything from a name, a photo, an email address, posts on social networking sites, medical information or a computer’s IP address. Personal data is not specifically defined by the legislation – regional differences need to accounted for.
• Employment history: CV/Resume, Design Work, Portfolios, Project Presentations, interview notes and interview feedback, e mail content, notes from telephone calls, salary and benefit package details, information in the public domain, such as Linked-In profiles and design work on design showcase sites.
We also collect, use and share data on behalf of candidates when contacting prospective employers in the execution of our commitment to assist in finding suitable employment as part of individual’s career development.
We do not use aggregated data such as statistical or demographic data for any purpose, nor do we use information about you from a visit to our website. Nor do we use information you have shared but asked for it not to be recorded.
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.

5. How data is collected:
We use several methods to collect data from and about you:
• Information you send to us either by email, post or in phone calls
• Research we conduct on behalf of our clients
• Information received through the interview process
• Information received from application forms you may be asked to complete
• Direct interactions with you
This date might typically include:
• Personal data you provide when you send your CV/Resume, Design Work, Portfolios, Project Presentations
• Email content, notes taken from phone calls, text messages, Skype and WhatsApp messages
• Data you request we retain on file for future potential positions.
• Information collected at interview stages, from telephone interviews and face to face interviews
• Information documented from clients with feedback from interviews, assessments or projects.
• Data and information that is in the public domain on professional sites like Linked-In and from designer showcase sites such as Arts Thread, Behance, Coroflot etc.
We also perform cursory research to identify potential candidates for specific roles from legitimate and bona-fide client companies. This research may include:
• Contact with mutual colleagues and acquaintances
• Internet research
• Historical personal experiences

6. Why we use your data:
When you contact Annette Cove Associates Limited, either via e-mail, through our website or other means, we will ask you to agree to the Annette Cove Associates Limited Privacy Policy and thereby give us consent to the processing of your personal information. If you decline to agree to this Policy and/or give us this consent, we regret that we will not be able to assist you with your job search or recommend you to our clients.
To enable us to assist you in finding an appropriate job, we will gather personal information about you from your CV, your portfolio and our interview process. See section 4 on what data we collect.
We hold and use this information to:
• Assist in finding an appropriate placement for both you, and for our clients.
• Communicate with you regarding job opportunities and the progress of any applications made on your behalf.
• To provide your details to appropriate prospective employers. We will only share your information with named prospective employers, and with your permission.
• Provide you with job alerts relating to roles we think you might be interested in.
• Provide you with help and advice to assist in your career development.
• Provide you with information about general trends in the world of footwear and accessories.
• Seek your feedback on our services.
• Fulfill our obligations to our clients when you are offered employment.

7. Disclosures of your data:
Apart from our role as recruitment consultants engaged in finding appropriate candidates for specific positions, we never share your personal information without your permission with anyone else outside of Annette Cove Associates Ltd, unless we are required to do so by law.
More specifically for candidates:
• Your information will only be shared with one of our clients relevant to your application for an open or a speculative role once we have confirmed your agreement for us to record your personal information, and have asked you if you wish to be considered for the open role or for your details to be sent speculatively to the client. You will have the opportunity to review your details before they are submitted to the client.
• 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 client organizations 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.
• Where we need to comply with a legal or regulatory obligation.
Some of our clients operate (or are based) outside the European Economic Area (EEA) therefore their own processing of your personal data may involve a transfer of data outside the EEA. We will not transfer any data outside of the EEA unless you have granted permission in writing at the start of a placement project.

8. 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 clients who have a legitimate business need to know. They will only process your personal data on our instructions and 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.

9. Data retention:
We will only retain your personal data for as long as necessary to fulfil the purpose for which it was originally collected. This includes the need to satisfy any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the following:
• 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 and retain your personal data
• whether we can achieve those purposes through other means
• Any applicable legal requirements.

10. Your legal rights:
Under the new GDPR criteria 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.
• 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.

If you wish to exercise any of the rights set out above, please contact us. You would not normally 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.
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.

If you have any concerns whatsoever with regards to our new GDPR compliant privacy policy, please do not hesitate to contact us for clarification on any point, or for further details of how this might affect you.
We are dedicated to providing a secure environment where clients can expect the highest levels of confidentiality and transparency, and candidates can be assured of their privacy and our exceptional duty of care.