Privacy statement for professional search (headhunting services)
What is our legal framework?
All personal data are processed in accordance with European Union data protection law, that is to say in line with Regulation (EU) 2018/1725 (‘EUDPR’).
Why do we process personal data?
Your personal data may be processed when the ECB engages headhunting (executive and professional search) service providers to identify potentially high-calibre candidates in some of the ECB’s external recruitment campaigns.
When the ECB engages a headhunting service provider to source potential candidates for a position, the provider puts forward potential candidates for specific campaigns by entering their first name, last name, email address and telephone number in the ECB recruitment system. This process is necessary to link the potential candidate to the headhunting service provider.
As a potential candidate put forward by a headhunting service provider, you can choose if you wish to apply for the position. To do so, you must provide the personal information required for the application. The headhunting service provider does not complete the application profile for you or apply for the position on your behalf. Information about the processing of personal data of applicants in the context of ECB recruitment activities can be found in the privacy statement for recruitment procedures.
To track the fulfilment of contractual obligations, the headhunting service provider and the ECB process information about the application status of potential candidates put forward by headhunting service providers. This information is also used by the ECB to manage and improve the process of selecting and recruiting staff members, including reporting and statistical analyses on aggregate and/or anonymised data.
Prior to putting forward a potential candidate for a vacancy at the ECB, and in all other interactions between the headhunting service provider and the potential candidate, the headhunting service provider is the controller of personal data in its own responsibility.
What is the legal basis for processing your personal data?
Your personal data are processed by the ECB in the performance of a task carried out in the public interest, based on Article 5(1)(a) EUDPR, in conjunction with Part 1A of the ECB Staff Rules.
Who is responsible for processing your personal data?
The ECB is the controller for the processing of your personal data. The People Services Division in the ECB’s Directorate General Human Resources and the headhunting service provider are responsible for this processing. The headhunting service providers used by the ECB are:
- Alexander Mann
- Egon Zehnder
- Harvey Nash
- Korn Ferry
- Michael Page
Who will be the recipients of your personal data?
The recipients of the data are designated ECB personnel in the Directorate General Human Resources, members of the selection committee, hiring managers, assistants, observers and assessors for each recruitment procedure and the appointing authorities, and the headhunting service provider acting as a data processor.
What categories of personal data are collected?
If the headhunting service provider wishes to put you forward as a potential candidate, they will enter the following information in the ECB recruitment system in order to create a temporary profile:
- your first name and last name;
- your email address;
- your telephone number.
You will receive an email and can then choose if you wish to apply for the position.
Your application status as a potential candidate put forward by the headhunting service provider is also tracked in the ECB recruitment system and can be accessed by the headhunting service provider.
How long will the ECB keep personal data?
If you create a profile within our recruitment system, your candidate profile will be retained for two years after you create or update your profile, or after we communicate the final outcome of your application. For further information, please refer to the privacy statement for recruitment procedures.
If you do not create a profile (i.e. choose not to apply), the temporary profile created by the headhunting service provider in the ECB recruitment system will be deleted after the closing date for applications and none of your information will be kept by the ECB.
What are your rights?
You have the right to access your personal data and correct any data that is inaccurate or incomplete. You also have (with some limitations) the right to delete your personal data and to object to or to restrict the processing of your personal data in line with the EUDPR. The ECB may restrict your rights to safeguard the interests and objectives referred to in Article 25(1) EUDPR.
Who can you contact for queries or requests?
You can exercise your rights by contacting join-us@ecb.europa.eu. You can also directly contact the ECB’s Data Protection Officer at dpo@ecb.europa.eu for all queries relating to your personal data.
Addressing the European Data Protection Supervisor
If you consider that your rights under the EUDPR have been infringed as a result of the processing of your personal data, you have the right to lodge a complaint with the European Data Protection Supervisor at any time.