PRIVACY CODE OF CONDUCT ON DATA PROTECTION

Purpose/Limitation:
EIM undertakes to process personal data only for the purpose of identifying, evaluating and selecting qualified candidates to fill positions in client organisations.
The candidate’s personal information can be transferred to other EIM offices and clients. EIM will always obtain a candidate’s unambiguous consent before sharing personal data with a client company.

Candidate Consent:
Prior to being interviewed for a position with a client organisation, candidates will be asked to sign a candidate consent form that authorises EIM to keep the candidate’s personal data in the Firm’s files and database. By such authorisation, the candidate will also agree to the following:
− That the candidate’s personal data may be handled for purposes of executive search activity; and
− That the candidate’s personal data can be transferred to EIM’s other offices and clients worldwide.

Unsolicited and solicited Curricula Vitae:
EIM receives unsolicited curricula vitae. Data subjects sending unsolicited curricula vitae to EIM would expect their personal data to be processed for the purposes of potential assignments. It would involve a disproportionate effort if EIM had to obtain the consent of each person who sends an unsolicited curriculum vitae in order to be able to keep his/her personal data in the Firm’s file and databases. EIM has, however, elected to inform such people of their rights of access and rectification by means of a letter of acknowledgement, and/or a statement on the Firm’s website.
Data subjects who send solicited curricula vitae to EIM, ie. People who are interviewed for a position with a client of the Firm, would be subject to the procedure described above in the section “candidate consent”.

Data Quality and Proportionality:
The data processed by EIM allows the consultant to locate a prospective candidate for a position and assess the candidate’s qualifications for the position. Among the categories of information that may be kept are the following:
− Name, professional and honorific titles
− Addresses, telephone numbers and e-mail addresses
− Employment history (company, position, title, responsibilities, reporting relationships, achievement, dates)
− Remuneration details
− Educational qualifications and professional credentials
− Languages spoken
− Any other professional skills, such as software knowledge
− Countries in which the individual has worked
− Details on the individual’s preferred geographic location and desired career path
− Marital status and number of children (to help predict the individual’s availability for a position where frequent travel is required), except in countries where this is prohibited
− Gender, except in countries where this is prohibited
− Age, except in countries where this is prohibited
− Nationality, expect in countries where this is prohibited
− Ethnic group, except in countries where this is prohibited

EIM will also keep records of the candidate’s contact history with the Firm. When the consultant has interviewed a candidate, notes of the consultant’s evaluation of the candidate’s professional experience and abilities will be kept. These notes will be dated and attributed to the individual consultant.

EIM may also keep notes containing assessments, opinions and reputations of the candidate, which are already in the public domain (such as press comments). EIM will not keep notes, which carry a risk of serious embarrassment or tarnishing of the candidate’s reputation unless the information is relevant and completely truthful.

EIM will also keep information regarding the candidate’s qualifications, which receive from former employers of the candidate and third-party references as well as information received in response to requests for verification of a candidate’s employment history and educational credentials.

EIM will not keep or process data revealing political opinions, religious or philosophical beliefs, trade-union membership, or data concerning an individual’s health or sex life.
Since the collection of statistics on racial or ethnic origin is requested in certain countries, but forbidden in to others, racial information and nationality will be systematically filtered according to the country of the viewing consultant. The same systematic filtering system will be applied to all categories of information (such as age, gender) which are viewed differently in different jurisdictions.

EIM will make reasonable efforts to assure that the personal data concerning candidates are accurate and complete and kept up to date.

Administration:
EIM will nominate one person per country to be responsible for the administration of all personal data in accordance with this Code of Conduct and the applicable laws of that country.
In addition, all employees who have access to personal data will be given a copy of this Code of Conduct and required to acknowledge in writing that they will abide by its provisions.

Transparency:
Candidates who are being interviewed by EIM for an assignment with a client organisation will be provided with the following information unless the candidate already has the information:
− The identity of the assignment counsellor
− The purposes for which the candidate’s personal data will be used
− The categories of potential recipients of the data
− The candidate’s right of access to certain data (outlined in section “Rights of Access”) concerning the candidate and the right to rectify such data
− Such further information as is necessary to guarantee fair processing with respect to the candidate.

Security:
EIM will take appropriate, state of the art, technical and organisational security measures to protect data against accidental or unlawful destruction, accidental loss, improper alteration, or unauthorised disclosure or access.

Rights of Access:
Candidates and other persons who are the subject of personal data in possession of EIM have a right to obtain the following information:
− Confirmation as to whether or not data relating to them are being processed.
− Information as to the purposes of the processing
− Information regarding the recipients to whom data are disclosed
− A copy of all data relating to them in the automated data processing systems of EIM that are accessible through a computer search of the candidate’s name
− The right to rectify any personal data that are shown to be inaccurate.

Restrictions on transfers to clients:
EIM will only pass on information to clients who acknowledge that they will adhere to the standards of data protection described in this Code of Conduct. Their acknowledgement will be required at the time the work for the client is contracted. A reiteration of this agreement will be included on each report containing candidate information which is passed to a client.

Direct Marketing Opt-Out:
If a candidate requests to receive no further contact from EIM this request will be respected and noted in the candidate’s personal file.

Automated Data Subject Decision:
EIM does not make automated data subject decisions, but decision support systems may be developed in the future. Where this is the case, a candidate will have the right to be informed of the logic underlying these systems.

The present Code of Conduct has been approved by the EIM Executive Committee on January 31, 2002.