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Nicole Brooke Policies

ISMS Policy:

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​Nicole Brooke Limited’s policy is to maintain an information management system designed to meet the requirements of ISO 27001:2013 in pursuit of its primary objectives, the purpose and the context of the organisation.

It is the policy of Nicole Brooke Limited to:

 

​Make the details of our policy known to all other interested parties including external where appropriate and determine the need for communication and by what methods relevant to the business management system.
 

Comply with all legal requirements, codes of practice and all other requirements applicable to our activities; therefore, as a company, we are committed to satisfy applicable requirements related to information security and the continual improvement of the ISMS.

Provide all the resources of equipment, trained and competent staff and any other requirements to enable these objectives to be met.

Ensure that all employees are made aware of their individual obligations in respect of this information Security Policy.

Maintain a management system that will achieve these objectives and seek continual improvement in the effectiveness and performance of our management system based on risk.

This information Security Policy provides a framework for setting, monitoring, reviewing and achieving our objectives, programmes and targets. To ensure the company maintains its awareness for continuous improvement, the business management system is regularly reviewed by “Top Management” to ensure it remains appropriate and suitable to our business. The ISMS is subject to both internal and external annual audits.

Scope:

The scope of this policy relates to use of the database and computer systems operated by the company in pursuit of the company’s business of providing human capital services to the financial services and legal sector. It also relates where appropriate to external risk sources including functions which are outsourced.

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Modern Slavery and Human Trafficking Statement 2021:

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This statement is made on behalf of Nicole Brooke Limited (the “Company”), headquartered in London, pursuant to of the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking.

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Nicole Brooke Limited operates in the executive search & recruitment field to provide permanent and interim senior staff for a global client base, on a business to business basis. The Company has employees in the UK, operating from 2 locations in the UK to help clients onboard HR professionals that will suit their organisation’s business needs.

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Our Commitment to Compliance:

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We are committed to complying with our legal and regulatory responsibilities under the Modern Slavery Act 2015 and will put strict measures in place to ensure that modern slavery is not part of any of our business operations. This includes our supply chains, goods and services.

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We work closely with our suppliers, clients and employees to maintain the highest level of compliance. We recognise that the actions of our business partners can affect our reputation and the level of trust that we earn from our clients. We hold our business, and associated stakeholders, to the highest possible ethical standards and do not tolerate any form of human rights abuse.

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Our Supply Chain:

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As an executive search and leadership talent advisory firm, our supply chain consists mainly of professional services suppliers. We engage a relatively small number of suppliers to provide services to our office such as cleaning and security, as well as products such as laptops and marketing materials. All suppliers are required to commit to key minimum standards relating to employment and workers. We will monitor our relationships and agreements with suppliers in order to eliminate modern slavery across associated supply chains. Whilst we operate in a sector that is relatively low risk for modern slavery and human trafficking, we continue to carry out due diligence on our suppliers.

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Organisational policies:

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Nicole Brooke Limited has introduced the following policies and principles to ensure we are applying satisfactory ethical standards to our work; Code of Business Conduct and Ethics; Corporate Social Responsibility; Grievance Procedure; Equal Opportunity Policy, Diversity Policy and Whistleblowing Policy. We are determined to ensure that, through the aforementioned policies, our interactions with clients, suppliers and other business partners, are in accordance with the legislation in the jurisdiction in which we operate.

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Signed by Nicole Brooke,

Managing Director, Nicole Brooke Limited

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Terms & Conditions:

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Introduction:
 

  1. These terms and conditions shall govern your use of our website.

  2. By using our website, you accept these terms and conditions in full; accordingly, if you disagree with these terms and conditions or any part of these terms and conditions, you must not use our website.

  3. Our website uses cookies; by using our website or agreeing to these terms and conditions, you consent to our use of cookies in accordance with the terms of our privacy and cookies policy.


Copyright notice:
 

​Copyright ©2024 Nicole Brooke Limited, Subject to the express provisions of these terms and conditions:

 

  1. we, together with our licensors, own and control all the copyright and other intellectual property rights in our website and the material on our website; and

  2. all the copyright and other intellectual property rights in our website and the material on our website are reserved.


Licence to use website:

 

You may:
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  1. view pages from our website in a web browser;

  2. download pages from our website for caching in a web browser;

  3. print pages from our website;

  4. stream audio and video files from our website; and
    subject to the other provisions of these terms and conditions.

  5. Except as expressly permitted by Section 3.1 or the other provisions of these terms and conditions, you must not download any material from our website or save any such material to your computer.

  6. You may only use our website for your own personal and business purposes, and you must not use our website for any other purposes.

  7. Except as expressly permitted by these terms and conditions, you must not edit or otherwise modify any material on our website.

  8. Unless you own or control the relevant rights in the material, you must not:

  9. republish material from our website (including republication on another website);

  10. sell, rent or sub-license material from our website;

  11. show any material from our website in public;

  12. exploit material from our website for a commercial purpose; or

  13. We reserve the right to restrict access to areas of our website, or indeed our whole website, at our discretion; you must not circumvent or bypass, or attempt to circumvent or bypass, any access restriction measures on our website.
     

Acceptable use:
 

You must not:
 

  1. use our website in any way or take any action that causes, or may cause, damage to the website or impairment of the performance, availability or accessibility of the website;

  2. use our website in any way that is unlawful, illegal, fraudulent or harmful, or in connection with any unlawful, illegal, fraudulent or harmful purpose or activity;

  3. use our website to copy, store, host, transmit, send, use, publish or distribute any material which consists of (or is linked to) any spyware, computer virus, Trojan horse, worm, keystroke logger, rootkit or other malicious computer software;

  4. conduct any systematic or automated data collection activities (including without limitation scraping, data mining, data extraction and data harvesting) on or in relation to our website without our express written consent;

  5. access or otherwise interact with our website using any robot, spider or other automated means;

  6. violate the directives set out in the robots.txt file for our website; or

  7. use data collected from our website for any direct marketing activity (including without limitation email marketing, SMS marketing, telemarketing and direct mailing).

  8. You must not use data collected from our website to contact individuals, companies or other persons or entities.

  9. You must ensure that all the information you supply to us through our website, or in relation to our website, is true, accurate, current, complete and non-misleading.
     

Limited warranties:
 

​We do not warrant or represent:
 

  1. the completeness or accuracy of the information published on our website;

  2. that the material on the website is up to date; or

  3. that the website or any service on the website will remain available.

  4. We reserve the right to discontinue or alter any or all of our website services, and to stop publishing our website, at any time in our sole discretion without notice or explanation; and save to the extent expressly provided otherwise in these terms and conditions, you will not be entitled to any compensation or other payment upon the discontinuance or alteration of any website services, or if we stop publishing the website.

  5. To the maximum extent permitted by applicable law and subject to Section 5.1, we exclude all representations and warranties relating to the subject matter of these terms and conditions, our website and the use of our website.
     

Limitations and exclusions of liability:
 

Nothing in a contract under these terms and conditions will:
 

  1. limit or exclude any liability for death or personal injury resulting from negligence;

  2. limit or exclude any liability for fraud or fraudulent misrepresentation;

  3. limit any liabilities in any way that is not permitted under applicable law; or

  4. exclude any liabilities that may not be excluded under applicable law.

  5. The limitations and exclusions of liability set out in this Section 6 and elsewhere in a contract under these terms and conditions:

  6. are subject to Section 6.1; and

  7. govern all liabilities arising under that contract or relating to the subject matter of that contract, including liabilities arising in contract, in tort (including negligence) and for breach of statutory duty, except to the extent expressly provided otherwise in that contract.

  8. To the extent that our website and the information and services on our website are provided free of charge, we will not be liable for any loss or damage of any nature.

  9. We will not be liable to you in respect of any losses arising out of any event or events beyond our reasonable control.

  10. We will not be liable to you in respect of any business losses, including (without limitation) loss of or damage to profits, income, revenue, use, production, anticipated savings, business, contracts, commercial opportunities or goodwill.

  11. We will not be liable to you in respect of any loss or corruption of any data, database or software.

  12. We will not be liable to you in respect of any special, indirect or consequential loss or damage.

  13. You accept that we have an interest in limiting the personal liability of our officers and employees and, having regard to that interest, you acknowledge that we are a limited liability entity; you agree that you will not bring any claim personally against our officers or employees in respect of any losses you suffer in connection with the website or these terms and conditions (this will not, of course, limit or exclude the liability of the limited liability entity itself for the acts and omissions of our officers and employees).
     

Breaches of these terms and conditions:
 

​Without prejudice to our other rights under these terms and conditions, if you breach these terms and conditions in any way, or if we reasonably suspect that you have breached these terms and conditions in any way, we may:
 

  1. send you one or more formal warnings;

  2. temporarily suspend your access to our website;

  3. permanently prohibit you from accessing our website;

  4. block computers using your IP address from accessing our website;

  5. contact any or all of your internet service providers and request that they block your access to our website;

  6. commence legal action against you, whether for breach of contract or otherwise; and/or

  7. suspend or delete your account on our website.
     

Where we suspend or prohibit or block your access to our website or a part of our website, you must not take any action to circumvent such suspension or prohibition or blocking (including without limitation creating and/or using a different account).
 

Variation:
 

We may revise these terms and conditions from time to time. The revised terms and conditions shall apply to the use of our website from the date of publication of the revised terms and conditions on the website, and you hereby waive any right you may otherwise have to be notified of, or to consent to, revisions of these terms and conditions.
 

Assignment:
 

  1. You hereby agree that we may assign, transfer, sub-contract or otherwise deal with our rights and/or obligations under these terms and conditions.

  2. You may not without our prior written consent assign, transfer, sub-contract or otherwise deal with any of your rights and/or obligations under these terms and conditions.
     

Severability:
 

  1. If a provision of a contract under these terms and conditions is determined by any court or other competent authority to be unlawful and/or unenforceable, the other provisions will continue in effect.

  2. If any unlawful and/or unenforceable provision of a contract under these terms and conditions would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect.


Third party rights:

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  1. A contract under these terms and conditions is for our benefit and your benefit, and is not intended to benefit or be enforceable by any third party.

  2. The exercise of the parties’ rights under a contract under these terms and conditions is not subject to the consent of any third party.


Entire agreement:
 

  1. Subject to Section 6.1, these terms and conditions, together with [our privacy and cookies policy], shall constitute the entire agreement between you and us in relation to your use of our website and shall supersede all previous agreements between you and us in relation to your use of our website.


Law and jurisdiction:
 

  1. A contract under these terms and conditions shall be governed by and construed in accordance with English law.

  2. Any disputes relating to a contract under these terms and conditions shall be subject to the exclusive jurisdiction of the courts of England.


Our details:
 

  1. This website is owned and operated by Nicole Brooke Limited

  2. We are registered in England and Wales under registration number 07761973


Privacy Policy:
 

This Privacy Policy explains how Nicole Brooke Limited collects, stores and processes your personal data.


Who we are:

We are Nicole Brooke Limited.

 

What do we do as a firm?
 

Nicole Brooke Limited engages in a number of human capital related services for its clients. This includes but is not limited to: executive search, executive interim, recruitment, market analysis projects, managed project delivery and due diligence.
 

As such the company gathers personal data to carry out these services to its clients. Personal information is stored, processed and transferred at various stages of these services both during and sometimes after client engagements are completed.
 

We are committed to engendering a culture of accountability, integrity and confidentiality in all aspects of the organisation in regard to personal data and security.
 

Purpose of this policy:
 

The purpose of this policy is to confirm how Nicole Brooke Limited uses your personal data. This policy has been amended in response to the General Data Protection Regulation that becomes enforceable in May 2018.
 

What does this policy cover?
 

  • The different types of data we collect about you

  • How and why we collect and use your personal data

  • How long we keep your personal data

  • What is the legal basis for using your personal data

  • When, how and why we share your personal data

  • What rights and choices you have when it comes to us using your personal data

  • How you can contact us
     

The data we collect about you:
 

We use your personal data to match your skills, experience and education with a potential employer. Initially we would collect basic information in relation to your name, contact details and job role in order to share with a potential employer. Once we have your permission we may gather and share more personal information from you in the form of a CV, compensation details and references, in assessing your suitability.
 

We may also need to collect sensitive personal information about you that may include your nationality, visa status and other information relating to any background screening we are required to provide future employers through our contractual obligations. We would only collect this information if you provide us with your consent to do so.
 

How do we collect your personal data?
 

We may collect personal data about you from the following sources:
 

  • From you directly

  • Publicly available sources

  • LinkedIn or other social networking sites

  • Corporate websites

  • References – by word of mouth
     

If you are not already known to Nicole Brooke Limited and we collect any of your personal data, we will let you know within 30 days of doing so. This will initially be via phone or email. If we collect any sensitive personal data (as outlined above), for such data, we require your explicit consent.
 

When signing up or registering on our website (www.nicolebrookeglobal.com) or a newsletter you will need to provide the necessary details asked for.
 

Why do we collect your personal data?
 

We collect personal data to enable us to match you to career opportunities that we have been engaged to work on by our clients. This may be for a permanent employment opportunity, temporary opportunity or a consulting engagement. Collecting and exchanging personal data is an essential process in order to assess suitability for potential roles, to build market insight and our client obligations. This is the legitimate interest as to why we collect and use your personal data.
 

How long do we keep your data for?
 

We will only keep your personal data for as long as we need to fulfil our client obligations or our legal requirements.

We have initially agreed to operate on the recommendation of the Association of Executive Search and Leadership Consultants (AESC) of holding data for 6 years. If there is no contact between you and Nicole Brooke Limited in this time, all your personal data will be securely deleted.
 

Legal basis for holding your data:
 

The basis for holding your personal data is determined on one or more of the following reasons:
 

  • Legitimate interest (outlined above) and where we will ensure the data is accurate and we have been transparent with you

  • Nicole Brooke Limited’s contractual obligations

  • Legal obligations under applicable law to retain records for a certain period

  • Your consent

  • Potential disputes

  • If you withdraw consent and request to be removed

  • Change in guidelines relating to data protection.
     

Who do we share your personal data with?

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We will only share your personal data with clients who have a contractual agreement with Nicole Brooke Limited to hire a position that may be relevant to you. We have a global client base operating in industries including, but not limited to, Financial Services and Professional Services sectors.
 

We may be required to transfer your personal data outside the EEA to Nicole Brooke Limited employees based in other international offices. We may also be required to transfer your personal data outside the EEA for a suitable role opportunity with one of our clients. Privacy laws in these countries may be different to your home country. Where we do transfer your data to a country which has not been deemed to provide adequate data protection standards we always have security measures in place to protect your data. To find out more please email dataprivacy@nicolebrookeglobal.com
 

Your basic personal data is also available to Nicole Brooke Limited employees. Sensitive personal data is restricted to certain employees or with third party suppliers who we contract with to support processing of payroll, screening processes or with government agencies.
 

Nicole Brooke Limited has a legitimate business interest in processing data to service its clients’ obligations. Processing would include, but not be restricted to, updating and keeping information accurate relating to: contact details; address; employment status; employers; roles; titles; compensation and a track record of correspondence through email, telephone conversations, face to face meetings or other communication. We recognise we have a requirement to ensure this data is accurate for the purposes of legitimate interest, contractual obligations and most importantly your rights as an individual.
 

Bank account data processing would only be incurred for those on the Nicole Brooke Limited payroll for contracting purposes (executive interim and consultancy agreements). We may also provide data to contracted third party providers who process data for us including IT services.

 

What are your rights?

 

By law you have certain rights available to you regarding your personal data. Further information is available from your country data regulator.

 

These include:

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  1. The right to be informed – you have the right to be provided with transparent, coherent information about how we use your data and your rights in relation to the use of your data. That is why we’ve provided this policy.

  2. The right of access – you have the right to access your information (if we are processing it) and certain other information (such as provided in this policy). This is so you are aware and check we are using it in accordance with the data protection law.

  3. The right to rectification – you have the right to have your information corrected if it is inaccurate or incomplete.

  4. The right to erasure – this enables you to request the deletion or removal of your information where there is no compelling reason for us to continue using it. There are exceptions to the right to erasure.

  5. The right to restrict processing – You have the right to “block” or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We will keep a list of those who have asked for it to be restricted so that their request is respected.

  6. The right to data portability – you have the right to transfer your personal data to another provider. You can move, copy and transfer data easily between our IT systems and their systems safely and securely without affecting its usability.

  7. The right to object to processing – you have the right to object to certain types of processing, including processing for direct marketing, including for the purposes of potential opportunities.

  8. The right to lodge a complaint – you have the right to make a complaint about the way we handle or process your data with your national data protection regulator.

  9. The right to withdraw consent – if you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw your consent with us for marketing purposes.

 

Access to your information:
 

You may request information about the personal data we hold. Subject access requests should be sent to dataprivacy@nicolebrookeglobal.com. Handling of these requests will be free of charge but we may charge a reasonable fee if we receive repeated or excessive requests or further copies of the same information. We will respond within 30 days of submitting the request.
 

Updates to this Policy:
 

We will keep this policy updated in response to changes in data privacy law and any changes to our business. Please review this policy for updates.

 

Cookies:

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We use cookies, pixels and tags (which we shall collectively define as “Cookies”) on our websites to personalise content and ads, to provide social media features and to analyse our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. You consent to our cookies if you continue to use our website. (www.nicolebrookeglobal.com)

 

How do you contact us?

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If you are unhappy with how we have handled your personal data, or have further questions on the processing of your personal data please contact us at: dataprivacy@nicolebrookeglobal.com

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Get in Touch

 

Nicole Brooke

Get in touch with the team using the contact details below. Alternatively just fill in the form and we'll be in touch soon!

 

+44 (0) 207 871 1485

hq@nicolebrookeglobal.com

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Thank you for getting in touch. We'll get back to you soon!

Nicole Brooke

80-83 Long Lane, London  EC1A 9ET

TELEPHONE: +44 (0) 20 7 871 1485

NICOLE BROOKE LIMITED  
REGISTERED IN ENGLAND NO. 07761973 

© 2024 NICOLE BROOKE GLOBAL

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