The Company is a recruitment business which provides work-finding services to both its clients and work-seekers. The Company must process personal data (including any 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, as a CV 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 statement in 1 below.
You comprise individual contacts at our clients and prospective clients, suppliers, service providers, business advisors and as candidate nominated referees. Your personal information will have been obtained by us through our normal business activities. The legal basis for processing this data and its use is in accordance with the terms of the statement in 1 below.
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 in relation to work-finding services. The legal bases we rely upon to offer these services to you are:
- Legal obligation
- Contractual obligation
- Legitimate interest
b. Recipient/s of data
The Company will process your data with its clients (for work-seekers), its IT and CRM support services (for data security), its auditors, legal advisors, and insurers together with organisations where it has a legal obligation to do so. Additionally, for work-seekers, to nominated persons/organisations for references.
c. Statutory/contractual requirement (work-seekers)
Before we introduce you to a client and/or offer you work on a Temporary Assignment, your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and, if you do not, the consequences of failure to provide the data means we cannot offer you work-finding services.
d. Legitimate interest (website users and business contacts)
We rely on legitimate interest as the legal basis for collection of data from our Website for statistical analysis purposes. We have a legitimate interest in analysing this data to ensure the information provided on our Website meets our business objective of attracting as wide a range as possible of candidates and clients seeking work-finding services in the areas of our speciality.
We do this by collecting information on how the Service is accessed and used. This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
We also rely on legitimate interest to process personal information relating to individual contacts at our clients and prospective clients, suppliers, service providers, business advisors and candidate nominated referees.
This personal information comprises, name, job title, work telephone number and work email address. It is retained for as long as the business relationship exists and thereafter to meet any legal and accounting obligations. Client contact and nominated referee personal information must be retained alongside work-seeker records under the Conduct of Employment Agencies and Employment Businesses Regulations 2003 (see 3 below).
Business contact personal information directly associated with accounting records such as invoices, purchases etc. will be kept for up to 6 full Tax Years.
2. Overseas Transfers (work-seekers)
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 (work-seekers)
The Company will retain your personal data only for as long as is necessary. Different laws 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 and any sensitive personal data we will do so in line with our Data Retention Policy below.
4. Data Retention Policy (work-seekers)
- We will retain your personal data for a period of two years from your initial registration or one year from last providing you with work finding services (whichever is the longer).
- If you have registered with us for Temporary Work and we do find work for you then we will retain your personal data for six full Tax Years from the end of the last Temporary Assignment on which you worked.
Upon expiry of the above periods, the Company may seek further consent from you. Where consent is not granted the Company will cease to process your personal data and any sensitive personal data.
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 personal data and any sensitive personal data, you have the right to withdraw that consent at any time by contacting the Company General Manager.
6. Complaints or Queries
If you wish to complain or have any queries about this privacy notice or any of the procedures set out in it please contact the Company General Manager.
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at 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.