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privacy promise

The Sector Five Privacy Promise:

to keep your data safe and private, not to use your data in ways you wouldn’t want, and to give you control over your personal information.

  1. What does this Policy cover?

  2. What personal information do we collect about you?

  3. Where do we collect this personal information from?

  4. How do we use your personal data?

  5. How long do we keep your personal data for?

  6. Who do we share your personal data with?

  7. What legal basis do we have for using your information?

  8. What happens if you do not provide us with the information we request or ask that we stop processing your information?

  9. Do we use Cookies to collect personal data on you?

  10. Do we transfer your data outside the United States or Japan?

  11. What rights do you have in relation to the data we hold on you?

  12. Your Rights under Data Protection Laws, and what they mean:

  13. How will we contact you?

  14. How can you contact us?

1.   What does this Policy cover?

Sector Five wants to make sure we use and look after your personal information properly. In addition to complying with all relevant Japanese privacy laws, the following explains more about how seriously we take the personal privacy of the individuals we work with as well as the very sensitive nature of the kinds of company information we are entrusted with.

This policy:

  • sets out the types of personal data that we collect about you

  • explains how and why we collect and use your data

  • explains how long we keep your personal data for; explains when, why, and with whom we will share your personal data

  • sets out the legal basis we have for using your personal data

  • explains the effect of refusing to provide the personal data requested

  • tells you about your privacy rights, the choices you have, and how the law protects you

  • explains how we may contact you and how you can contact us

2.   What personal information do we collect 

      about you?

We gather the information we need to find available opportunities and the best candidates to fill them. To be able to assess eligibility through the different stages of recruitment we will collect personal information about you such as name, job title, work history, email addresses, and telephone numbers.

If we have considered you for an opportunity, we may record CVs, skills, educational records, identification documents, and employment references as well as information on your suitability as part of our assessments of your professional profile, and this would include information on your personal and professional life publicly available on social media services (LinkedIn, Facebook, Google, Twitter, etc.), or elsewhere on the internet, relevant to the position.

We may also collect sensitive personal data about you, in the form of remuneration, equal opportunities for monitoring information, and entitlement to work. We only collect sensitive personal data from you, and further process this data, where you have given your explicit consent.

If you are receiving coaching from us, we will also process any additional information that you choose to provide to us during the course of the coaching.

3.   Where do we collect this personal

      information from?

Through publicly available sources such as company websites, social media & networking sites, internet search engine results, press articles, awards granting bodies, and also through subscription-based services which monitor agency-client relationships and advertising output.
Directly from you. This is information you provide while searching for a new opportunity and/or during the different recruitment stages.
By reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague, or even a present employer.

4.   How do we use your personal data?

We use your personal data to match your skills, experience, and education with a potential employer, and also to provide our clients with market and talent maps showing the general pool of talent currently employed within specific industries and sectors. We will initially collect basic information on you such as job role and experience and we may then pass this on to the client in search of personnel. If you are chosen by the client or our consultants and go through to the next stage we will then be collecting more information from you at the interview (or equivalent) stage and onwards in that manner.If you are receiving coaching from us, we use your personal data in order to understand more about you and to assist you with understanding your skills and areas for improvement or future opportunities and options.

5.   How long do we keep your personal data for?

We aim to build life-long relationships. If you are employed within our target industries we aim to keep your information for your working life to ensure that we can consider you for all relevant opportunities in the future.

We may also keep your data if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes

In other cases, we only keep your information while we use it.

When deciding how long to keep your data, we will take into account:
(a) our contractual obligations and rights in relation to the information involved;
(b) legal obligation(s) under applicable law to retain data for a certain period of time;
(c) statute of limitations under applicable law(s);
(d) (potential) disputes;
(e) if you have made a request to have your information deleted;
(f) guidelines issued by relevant data protection authorities; and
(g) our legitimate interest where we have carried out a balancing test (see legal basis below).

Otherwise, we securely erase your information once this is no longer needed.

6.  Who do we share your personal data with?

We share your data with the client who has a position to fill, to determine with the client whether you are a good fit for the available position. Our clients come from a broad range of sectors and geographies.

We may also conduct checks on you to verify the information you have provided and where we do this we share your information with relevant providers.

Sector Five operates globally without borders, and consultants in all markets will have access to the data we hold to ensure global searches are truly global.

Sector Five will never share confidential information that you have shared with us outside our organization without your explicit consent (except for purely operational reasons where we may share your data with our database supplier, and contractors performing specific roles within our broader staffing complement, such as those supplying freelance research and consulting services.

7.  What legal basis do we have for using your information?

Suppose we include information about you on a talent or market map or anonymized information on a salary survey. For prospective candidates, interim managers, referees, and clients, our processing of your data are essential to enable us to understand the market. In that case, we operate to assess your suitability for potential roles, find potential candidates and contact clients and referees. So we rely based on this legitimate business interest.

We carry out a ‘balancing test’ to ensure that our processing is necessary and that our legitimate interests do not outweigh your fundamental rights to privacy. We keep a record of these balancing tests. You have a right to and can find out more about the information in these balancing tests by contacting us using the details below.

Suppose you are shortlisted as a candidate or coached by us. In that case, this may involve processing more detailed personal data, including sensitive data such as health information that you or others provide about you. In that case, we always ask for your explicit consent before undertaking such processing.

For clients, we may also rely on our processing being necessary to perform a contract for you, for example, in contacting you.

8.  What happens if you do not provide us with the information we request or ask that we stop processing your information?

If you do not provide the personal data necessary or withdraw your consent for the processing of your personal data, we may not be able to match you with available job opportunities.

9.  Do we use Cookies to collect personal data on you?

To provide better service to you on our websites, we may use cookies to collect your personal data when you browse.

10.  Do we transfer your data outside the United States or Japan?

To better match your employee profile with current opportunities, we may transfer your data to clients and partners in countries outside the United States or Japan. These countries' privacy laws may differ from those in your home country.

We transfer personal data to the following countries outside the United States with offices or affiliates: Japan, China, Singapore, EEA, and Australia.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. In particular, this means that your data may be transferred to a country that provides an adequate level of protection (for example, where the European Commission has determined that a country has top-level security) or where standard contractual clauses bind the recipient according to conditions provided by the European Commission ("EU Model Clauses").

To find out more about how we safeguard your information related to transfers, please contact us.

11.  What rights do you have in relation to the data we hold on you?

By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.

12.  Your Rights under Data Protection Laws, and what they mean:

You have the right to object to our use of your personal information or to ask us to delete, remove, or stop using your personal information if we don't need to keep it. There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think we should not be using it.

These rights in more detail:

  • The right to be informed - you have the right to be provided with clear, transparent, and easily understandable information about how we use your information and your rights, which is why we are providing you with the information in this Policy.

  • The right of access - you have the right to obtain access to your information (if we are processing it) and certain other information (similar to that provided in this Privacy Policy). We state this, so you know and can check that we're using your information under data protection law.

  • The right to rectification - you are entitled to have your information corrected if it's inaccurate or incomplete.

  • The right to erasure is also known as 'the right to be forgotten. It enables you to request the deletion or removal of your information where there's no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

  • The right to restrict processing - you have the right to 'block' or suppress further use of your information. We can still store your data when processing is restricted but may not use it further. We keep lists of people who have asked for further use of their information to be 'blocked' to ensure the restriction is respected in the future.

  • The right to data portability - you have the right to obtain and reuse your data for your purposes across different services. For example, suppose you decide to use another provider of recruitment and search services. In that case, this enables you to move, copy or transfer your information quickly between our IT systems and theirs safely and securely, without affecting its usability. You should note that this applies only to the information you have supplied to us.

  • The right to object to processing - you have the right to object to certain types of processing, including processing for direct marketing (i.e., if you no longer want to be contacted with potential opportunities).

  • The right to complain - you have the right to complain about the way we handle or process your data with your national data protection regulator.

  • The right to withdraw consent - if you have given your consent to anything we do with your 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 data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your data for marketing purposes.


We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

  • baseless or excessive/repeated requests

  • further copies of the same information.


Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We'll respond as soon as we can. Generally, this will be within one month from when we receive your request, but if the request takes longer to deal with, we'll come back to you and let you know.

13.  How will we contact you?

We may contact you by phone, email, or social media. If you prefer a particular contact means over another please just let us know.

14.  How can you contact us?

If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact us through the contact details provided on our website.

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