Collection and use of personal data
Purpose of processing and legal basis
The Company has collected 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. The legal bases we rely upon to offer these services to you are:
- Legitimate interest
- Legal obligation
- Contractual obligation
The legal circumstances in which we will share your data are as follows:
- We receive a summons, court order or other legal demand for your information
- We believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, or as otherwise required by law.
Categories of data
The Company has collected the following personal data on you:
- Name/contact details
- Evidence of right to work in the UK for example copy of passport, proof of address, National Insurance number, Bank details, Limited company details, Limited company bank details, evidence of certifications
- Curriculum Vitae
Sensitive personal data:
- Evidence of Disclosure Scotland,
- Credit and criminal record checks
Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
- For the purpose of seeking suitable employment opportunities
Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients:
- Suitable clients
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.
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 sensitive personal data, we will do so in line with the stated retention policy on the consent form. 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 data and sensitive personal data
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 sensitive personal data you have the right to withdraw that consent at any time by contacting:
Sally Field – Data Protection Manager
Gary Duckman – Data Protection Officer
See opening statement for contact details
Source of the personal data
The Company sourced your personal data/sensitive personal data either as a result of a direct personal response, or from a publicly accessible source:
- Job Boards
Complaints or Queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact:
- Sally Field – Data Protection Manager
- Gary Duckman – Data Protection Officer
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.
We understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means the website owner
2. What Does This Policy Cover?
3. Your Rights
3.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
3.1.1 The right to be informed about Our collection and use of personal data;
3.1.2 The right of access to the personal data We hold about you.
3.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete;
3.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us);
3.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
3.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
3.1.7 The right to object to Us using your personal data for particular purposes; and
3.1.8 Rights with respect to automated decision making and profiling.
3.2 If you have any cause for complaint about Our use of your personal data, please contact Us and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
3.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
4. What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data:
4.2 business/company name
4.3 job title;
4.5 contact information such as email addresses and telephone numbers;
4.6 demographic information such as post code, preferences and interests;
4.7 IP address;
4.8 web browser type and version;
4.9 operating system;
4.10 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
5. How Do We Use Your Data?
5.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times.
5.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
5.2.1 Providing and managing your access to Our Site;
5.2.2 Personalising and tailoring your experience on Our Site;
5.2.3 Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
5.2.4 Personalising and tailoring Our services for you;
5.2.5 Replying to emails from you;
5.2.6 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time;
5.2.7 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.
5.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and/or post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
5.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
5.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
6. Do We Share Your Data?
6.1 Subject to section 6.2, We will not share any of your data with any third parties for any purposes.
6.2 We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
6.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
6.4 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
6.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
7. What Happens If Our Business Changes Hands?
7.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
8. How Can You Control Your Data?
8.1 When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
8.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
9. Your Right to Withhold Information
9.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
10. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable, and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details available on our website.
11.2 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
11.3 Before Cookies are placed on your computer or device, you will be shown a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
11.4 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
11.5 Our Site uses analytics services. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
11.6 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
11.7 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
11.8 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
11.9 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
12. Contacting Us