The Company is a recruitment business which 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 the terms of the following statement.
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, adding your details to our databases, putting you forward for job opportunities (which includes passing your details on to third parties), arranging payments to you and developing and managing our services and relationship with you and our clients.
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.
The legal bases we rely upon to offer these 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:
- Managing our database and keeping work-seeker records up to date;
- Contacting you to seek your consent where we need it;
- Providing work-finding services to an individual, including sending their information to your clients where they have demonstrated an interest in doing that particular type of work but not expressly consented to you passing on their cv;
- Contacting the individual with information about similar products or services that they have used from you recently; and
C. Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients:
- Clients that we introduce or supply individuals to for the purposes of providing work-finding services
- Candidates’ former or prospective new employers that you provide as part of the recruitment process
- Payroll service providers Sage
- Our legal advisers if necessary
- Our IT suppliers HBP Ltd, and our CRM provider Voyager.
- Should a client require background checks (such as DBS, Credit checks, previous Directorships etc), we will pass your personal details on to Annurca Risk who will carry out these checks. We will always inform you if this is happening and seek your additional consent
- Should a client request that a candidate completes psychometric testing, we will share your personal data with our test provider Thomas International
- We may use public databases to carry out suitability checks on work-seekers e.g. Companies House, DVLA
- Government, law enforcement agencies and other regulators e.g the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI), Local Authority Designated Officers (LADOs), GLAA
We will always make it clear to you as a work-seeker where and with whom we are sharing your data.
2. Overseas Transfers
The Company may transfer only 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 and Liechtenstein.
3. Data retention
The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.
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.
Where the Company has obtained your consent to process your personal/sensitive data, we will do so in line with our retention policy. This stipulates that we will only keep personal data as long as is necessary, and we will review the bases for holding your data in the instance that we have not engaged with you in over 1 year. 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 personal/sensitive data.
4. 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 personal/sensitive data you have the right to withdraw that consent at any time by contacting Caritia Stanforth on firstname.lastname@example.org or 0113 834 3170.
There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting 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.
5. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Caritia Stanforth
E: email@example.com T: 0113 834 3170
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.
Withdrawal of consent
We take our candidate’s privacy and data protection very seriously, and we respect your right to withdraw your consent for us to process your personal data on our systems. Should you wish to withdraw your consent, please download our Withdrawal of Consent form here and send it to firstname.lastname@example.org
Alternatively, if you have issues downloading the form, please send an email with your full name and details of your request to withdraw your consent to email@example.com and we will ensure your details are deleted.