The Company is a recruitment business that provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.
You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws.
1. Collection and use of personal data
a. Purpose of processing and legal basis
b. Legitimate interest
c. Statutory/contractual requirement
d. Recipients of data
2. Information to be provided when data is not collected directly from the data subject
a. Categories of data
b. Sources of data
3. Overseas transfers
4. Data retention
5. Your rights
6. Automated decision making
8. Login files
9. Links to external sites
10. Sale of the business
11. Data security
12. Changes to this privacy statement
13. Complaints or queries
1. Collection and use of personal data
a. Purpose of processing and legal basis
The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes, for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you
and our clients.
If you have opted-in we may also send you marketing information and news via email/text. You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.
In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:
• Your consent
• Where we have a legitimate interest
• To comply with a legal obligation that we have
• To fulfil a contractual obligation that we have with you
b. Legitimate interest
This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
• To provide and undertake recruitment services;
• To assess data against vacancies the Company judge may be suitable for you;
• To send your information to clients so they can receive your application or assess your eligibility for jobs;
• To enable you to submit your CV or apply for jobs;
• To improve the Company’s service and to make the Company’s services more relevant to you (including updating
the Company’s website to enhance your digital experience);
• Where you have consented to being contacted, send you promotions, offers, networking events and market
• To answer your queries;
• To carry out our obligations arising from any contracts entered into between you and the Company, or any contracts the Company enters into with third parties in relation to providing you recruitment services;
• To facilitate the Company’s payroll and invoicing processes;
• To third parties that undertake references, qualifications and criminal reference checking services, the verification of the details you have provided from a third-party source, psychometric or skills evaluation;
• To third parties, regulatory or law enforcement bodies if the Company believes that they are required to disclose it in connection with a crime, the collection of taxes/duties, or in order to observe an applicable law or legal proceedings.
c. Statutory/contractual requirement
The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some
circumstances safeguarding requirements.) Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us personal data we need to collect we may not be able to continue to provide work-finding services to you.
d. Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients:
• Any of the Company’s branches;
• Third parties who require reference information relating to your past or future employment;
• Third party services providers who supply processing services or perform functions on the Company’s behalf;
• Outsourced IT and document storage providers that the Company has entered into contractual agreements with;
• Marketing technology suppliers and platforms;
• MSP and RPO suppliers, where the Company’s clients utilise these suppliers.
2. Information to be provided when data collected not from the data subject.
Categories of data: The Company has collected the following personal data on you:
• Contact number
Source of the personal data: The Company sourced your personal data:
• From jobs boards, LinkedIn and company websites
• A former employer
• A referee whose details you previously provided to us
• Cookies listed in section 7
This information came from a publicly accessible source.
3. Overseas Transfers
The Company may transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland
4. Data retention
The Company will retain your personal data only for aslong as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently three to six years.
Where the Company has obtained your consent to process your sensitive personal data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your sensitive personal data.
In addition to our obligations under the Conduct of Employment Agencies and Employment Businesses Regulations 2003, the Company will delete your personal data after three years if we have not had any meaningful contact with you or if we do not hold any records on you that are in our legitimate interests to keep.
“Meaningful contact” means, for example, any form of contact between us in relation to the Company
assisting/providing recruitment services to you.
5. Your rights
Please be aware that you have the following data protection rights:
• The right to be informed about the personal data the Company processes on you;
• The right of access to the personal data the Company processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to automated decision making and profiling; and
• The right to withdraw consent at any time.
Where you have consented to the Company processing your sensitive personal data you have the right to withdraw that consent at any time by contacting us at firstname.lastname@example.org
Please note that if you withdraw your consent to further processing, this does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.
There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
6. Cookies Policy
We may obtain data about you from cookies. These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.
The cookie-related information is not used to identify you personally and the pattern data is fully under our control.
These cookies are not used for any purpose other than those described here. The only third-party cookies we use on our site are Google Analytics (please see below on Google Analytics)
Strictly necessary cookies
These cookies are needed for effective site usage and, as such, cannot be turned off.
These cookies do not gather information about you that could be used for other purposes, such as marketing or tracking your Internet usage.
Performance cookies These cookies help us monitor and improve the performance of our website, counting
visits, identifying traffic sources and judging site popularity. We use Google Analytics for this purpose, but all information gathered is anonymous.
Functionality cookies These cookies remember choices you make upon first visiting our website, including user name, language or where you are based. This allows the website to remember changes you have made to text size, font and other customisable elements. It also prevents repeat processes such as pop-ups. Functionality cookies may also be used to provide services you wish to use, such as watching video and commenting, and are usually anonymous.
such third parties use the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
Most web browsers allow some control of most cookies through the browser settings.
7. Log Files
We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
8. Links to external websites
The Company’s website may contains links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.
9. Sale of business
If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
10. Data Security
The Company takes every precaution to protect our users’ information. The Company uses the following security measures to safeguard your data;
• Firewalls including anti-spyware software
• Anti-virus software
• Anti-spam filters
• All data is backed up daily
• All files/data are stored on password protected systems
Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information.
The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/the Internet.
If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered.
If you have any questions about the security at our website, you can email us at email@example.com.
11.Changes to this privacy statement
Any changes to this Privacy Statement will be updated on this website as and when it is required. If at any time we use personal data in a significantly different manner than from stated in this statement, we will notify you and you will be able to decide if we are able to use this information in the new manner.
12.Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact us at firstname.lastname@example.org
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.
a) The lawfulness of processing conditions for personal data are:
1. Consent of the individual for one or more specific purposes.
2. Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract.
3. Processing is necessary for compliance with a legal obligation that the controller is subject to.
4. Processing is necessary to protect the vital interests of the individual or another person.
5. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of
official authority vested in the data controller.
6. Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the
individual which require protection of personal data, in particular where the individual is a child.
b) The lawfulness of processing conditions for sensitive personal data are:
1. Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited
by EU or Member State law.
2. Processing is necessary for carrying out data controller’s obligations under employment, social security or social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental
rights and interests of the individual.
3. Processing is necessary to protect the vital interests of the individual or another individual where the
individual is physically or legally incapable of giving consent.
4. In the course of its legitimate activities, processing is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the consent of the individual.
5. Processing relates to personal data which are manifestly made public by the individual.
6. Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
7. Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law which shall be proportionate to the aim pursued, respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the individual.
8. Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional and subject to the necessary conditions and safeguards.
9. Processing is necessary for reasons of public interest in the area of public health, such as protecting against
serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of
medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable
and specific measures to safeguard the rights and freedoms of the individual, in particular professional
10. Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.