AFM PRIVACY STATEMENT

Advance Financial Management Ltd. ("AFM") is a company engaged in the recruitment and head-hunting industry, specialising in, but not limited to, the shipping, commodities and finance markets, matching candidates with clients and vice versa. In order to do this, we need to create, keep and process personal (occasionally sensitive) data.

Your privacy is very important to us at AFM. This Privacy Statement provides details about the personal information that AFM collects, the ways in which AFM uses that personal information, and your rights in respect of that information (also referred to as 'data').

General Terms

If you submit personal data to us either in writing, electronically or verbally, you are consenting to our use, processing and transfer of such data on the terms laid out in this Privacy Statement. If this is not acceptable, we would request you not to give us such data.

If you wish to exercise your "right to be forgotten", you may request us to delete your data, and we will comply with that request, except in the circumstances listed lower down in this Statement.

Data stored by AFM is only accessible by direct employees or its technical support staff, all of whom are aware of the importance of data privacy and security and of their and our obligations under data protection regulations.

If you contact us and/or apply for any vacancies we are handling, you need to agree to our Use of This Website Terms and Conditions, which are published elsewhere on our website, and this Privacy Statement, which should be read along with those Terms and Conditions.

AFM strongly believes in protecting the privacy of all users of our website, and takes all reasonable and prudent precautions to protect our users' personal data and information; however, the use of the internet is not entirely secure and for this reason we are not able to absolutely guarantee the security or integrity of any personal data which is transmitted from you or to you via the internet. If you believe that your data may have been misused or compromised, please advise us immediately.

Processing of personal data

The legal basis

Under the General Data Protection Regulations (GDPR) which came into force on 25th May 2018 in relation to the EU and various other countries, we are obliged to have a legal basis for the processing of personal data, which we do mainly in order to assist candidates with finding job opportunities and clients with finding potentially suitable candidates.

One of the acceptable legal bases for the processing of personal data under the GDPR is "legitimate interests". The Information Commissioner's Office of the GDPR has advised that this basis for data processing is likely to be most appropriate where people's data is used in ways they would reasonably expect and which have a minimal privacy impact (and without overriding the interests, rights or freedoms of the data subject). The Information Commissioner's Office has also advised that "legitimate interests" may be an acceptable basis for sending emails and text messages and otherwise contacting candidates and clients.

The Commissioner's Office has suggested a three-part test to satisfy the "legitimate interests" basis:

1.  Identify a legitimate interest;
2.  Show that the processing is necessary to achieve it - the necessity test (are there alternative ways to achieve the same result?); and
3.  Balance it against the individual's interests, privacy, rights and freedoms.

With these tests in mind, AFM has reached the following conclusions:

Legitimate Interest: AFM has a legitimate interest in the growth of its business and fulfilling the broader purpose of providing a useful service to candidates and clients.

Necessity: AFM believes that collecting candidates' details, via CV's, email and other means of electronic and telephonic communication, social media, social networking sites such as LinkedIn, networking, the exchange of business cards and research within the public domain (company websites, advertisements, publications, brochures, etc.) and storing the same in a secure database is necessary for this purpose, and enables us to provide a more personalised service, and that there are no alternatives to achieve the same ends.

Balance: Looking at the above, AFM believes that the balance comes down on the side of acceptability of the data processing it undertakes. It also believes that people working in the markets covered by AFM will expect and accept that their business contact details and other information will be processed by AFM.

What information we collect and how we do it.

•  a) Candidates

In order to best enable us to assist you in finding your next position, AFM may collect and store your personal data, including, but not limited to, your name, contact details, career history, qualifications, sex, date of birth, education, nationality, residential status, salary and other relevant information (some of which may be of a sensitive personal nature).

This is undertaken through various methods, including:

•  Our website, if you send us your CV and/or apply for positions;
•  Correspondence in writing, electronically or telephonically;
•  Face-to-face meetings;
•  Contact with third parties introduced by you, such as referees, schools, former employers, professional bodies etc..
•  Social networking websites such as LinkedIn;
•  Social media channels.

In order to ensure that our data is current, we may contact you from time to time.

•  b) Clients

 In order to maintain good communication with clients, we obtain and process data from various channels, including personal contact or recommendation, meetings, correspondence (in writing, electronically or telephonically), social networking sites, conference attendance lists and information in the public domain. This is usually limited to names and contact details.

What we use it for and how

Your personal and corporate data is created and processed by us so that we can provide the best possible services, especially in the fields of introduction of candidates to new positions or provision of suitable candidates to our clients.

•  a) Candidates

We maintain a secure database in which we store data about candidates. In addition to the raw data, we also store notes of conversations and other communication and additional relevant information. We are able to search in this database using various criteria, and this enables us to most efficiently find candidates who match the requirements laid out by clients who have instructed us to carry out a search for a particular position.

If you are such a candidate, we may then contact you, explain the position and ask whether you are interested to know more and/or be considered for that position. We may also discuss further with you in person or over the phone or by other means of communication, and eventually request your permission for us to send your CV to the client, of course on a strictly confidential basis and for that client only. We will always request your permission before submitting your CV to any other clients.

•  b) Clients

We want to be able to give you the best possible service and send you the most suitable possible candidates, and therefore we enter and process into our database details of your organisation and relevant contacts as well as notes of conversations, other communication and additional relevant information. We consider this to be part of our legitimate interest in the provision of recruitment services to you.

Sharing of personal data

In the course of our business, we may share your data with other parties, as follows:

•  a) Candidates
•  Our clients, but only with your prior permission, as we seek to find employment for you;
•  Our technical support staff, but only as far as is required for them to carry out their duties;
•  Any other recruitment companies who may, rarely, be involved in the recruitment process;
•  Any authorities whose laws or regulations we need to follow.
•  b) Clients
•  Our candidates;
•  Our technical support staff, but only as far as is required for them to carry out their duties;
•  Any authorities whose laws and regulations we need to follow.

Data Retention Policy

Unless you request us otherwise, AFM will retain your personal data for as long as we believe that you may potentially be interested in a new position. People stay in jobs for varying lengths of time, and it could be said that almost everyone is a candidate if the right position becomes available.

What are your rights?

You have the following rights:

•  a right of access to a copy of the information comprised in your personal data;
•  a right to object to processing that is likely to cause or is causing damage or distress.
•  a right to prevent processing for direct marketing;
•  a right to object to decisions being taken by automated means;
•  a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed;
•  The right to withdraw consent to our retention of your data at any time (subject to particular exceptions). Particularly in the case of any sensitive information, we will need to have your initial consent, and in such case you have to give your consent freely and understand what it is that you are consenting to.

Data viewing/editing/removal

AFM is fully committed to giving those on whom data is processed the right to view that data, and ask that it be edited or removed. The only situations in which AFM will not be able to accept a request for removal will be insofar as it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, or in order to establish, exercise or defend its legal rights.

Cross-border data transfers

Information that AFM collects may be stored and processed in and transferred between any of the countries in which AFM and its clients operate to enable the use of the information in accordance with this Privacy Statement.

In addition, any personal information that you submit for publication on the website will be published on the internet and may be available around the world.

You agree to such cross-border transfers of personal information.

Other websites

AFM' website may from time to time contain links to other websites. AFM is not responsible for the privacy policies or practices of any third party.

Unsubscribe

If you do not wish to receive any marketing or other communications from us, you can withdraw your consent by advising us at any time.

Data Protection Officer

AFM's Data Protection Officer is Mr. Robin Lambert, contactable via email using this form.

Contact AFM

If you have any questions about this privacy policy or AFM's treatment of your personal information, please write:
by email using this form.
Or by post to:
2310 Dominion Centre, 43-59 Queen's Road East, Wan Chai, Hong Kong.