The personal data we collect or receive includes the following as applicable:
We may obtain your personal data from the following sources (please note that this list is not exhaustive):
The processing of your personal information may include:
1. Entering into a contract with you:
In order to provide our Recruitment Services we may enter into a contract with you and/or a third party. In order to enter into a contract we will need certain information, for example your name and address. A contract will also contain obligations on both your part and our part and we shall process your data as is necessary for the purpose of those obligations.
2. Compliance with legal obligations (regulatory and statutory obligations):
We must comply with a number of statutory provisions when providing our Recruitment Services, which necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which amongst other things requires us to:
We are also required to comply with statutory and regulatory obligations relating to business generally, for example complying with tax, bribery, fraud/crime prevention and data protection legislation, and co-operating with regulatory authorities such as HMRC or the Information Commissioner’s Office.
3. Our legitimate interests (carrying on the commercial activity of Recruitment Services):
In providing our Recruitment Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include:
Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
Using your personal data to:
This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes.
4. Consent to our processing of your data:
We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you apply for a specific role you may have consented to our processing of the data that has been provided for the purpose of progressing your application and considering your suitability for that role. In other cases you may have provided your written or verbal consent to the use of your data for a specific reason.
You may withdraw your consent to our processing of your personal information for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.
Part of our business activity involves researching information relating to individuals for the purposes of filling job roles. This may include obtaining personal data from online sources, for example we may obtain information from social media sites such as LinkedIn and job boards, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal information about you from hiring organisations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged.
Where information from third party sources is of no use to us, or where you have notified us that you do not want us to provide you with services, we shall discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Recruitment Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see Section 4 – “Your rights”.
Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our consideration of your suitability for a job role. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.
Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that data for the purposes of our relationship with you or for the provision of our Recruitment Services. This will be for one or more of the following reasons:
We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information include:
We do not use any automated decision making software.
We may collect your personal data in the course of our dealings and this may include the following:
We may obtain your personal data from the following sources (please note that this list is not exhaustive):
We will process your personal data in the context of our dealings with the third party for whom you work and as part of our Recruitment Services. Processing may include:
1. Compliance with legal obligations (regulatory and statutory obligations):
We must comply with a number of statutory provisions when providing our Recruitment Services, which necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which amongst other things requires us to assess suitability of candidates and obtain information from Clients.
We are also required to comply with statutory and regulatory obligations relating to business generally, for example tax, bribery and fraud/crime prevention legislation, and co-operating with regulatory authorities such as HMRC.
2. Our legitimate interests (carrying on the commercial activity of Recruitment Services):
In providing our Recruitment Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include:
Using your personal data:
Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
For our commercial viability and to pursue these legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate for these purposes.
Consent:
We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you have provided your contact details in order that we may use these to provide you with details of our services you may have consented to our processing of the data for that purpose. In other cases you may have provided your written or verbal consent to the use of your data for a specific reason, for example references.
You may withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.
Part of our business activity involves researching information for the purposes of finding and filling job roles. This may include obtaining personal data from sources including job boards, advertisements, LinkedIn or other social media, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal data about you from hiring organisations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged.
Where information from third party sources is of no use to us we shall discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Recruitment Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see Section 4 -“Your rights”.
Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our dealings with you in respect of our Recruitment Services. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.
Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that personal data for the purposes of our relationship with you or for the provision of our Recruitment Services. This will be for one or more of the following reasons:
We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information include:
Transfer – In the event of a sale, merger, liquidation, receivership or the transfer of all or part of our assets to a third party, we may need to transfer your information to a third party. Any transfer will be subject to the agreement of the third party to this Privacy Notice and any processing being only in accordance with this Privacy Notice.
Data Security and Confidentiality – It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not accessible to unauthorised third parties in line with contemporary practice.
Cookies – a coolie is a smalll file of letter and numbers that is downloaded on to your computer when you viist a website, which eables the website to tailr its offerings to your preferences when you visit it. We use cookies on your website
Retaining your data – It is our policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests. If however you believe that we should delete your personal data, please inform us in writing of your reasons. Please see Section 4 ‘Your Rights’ below
Changes to this privacy notice – This Privacy Notice is regularly reviewed and may be updated from time to time to reflect changes in our business, or legal or commercial practice.
We take the protection of your personal data very seriously and it is important that you know your rights within that context, which include rights to:
– Request a copy of the personal data that we hold
– Object to our processing of your data where that processing is based upon legitimate interest and there are no compelling grounds for the continued processing of that data
– Request that we restrict processing of your data in certain circumstances
– Request that data is erased where the continued use of that data cannot be justified
– Object to any decision, which significantly affects you, being taken solely by a computer or via another automated process
– Withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations
– Request that inaccurate or incomplete data is rectified
– Request that data provided directly by you and processed by automated means is transferred to you or another controller; this right only being applicable where our processing of your data is based either on your consent or in performance of a contract
– Make a complaint to the Information Commissioner’s Office Request that direct marketing by us to you is stopped
Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken in order to both evidence our compliance, and to take steps to minimise the prospect of any data being processed in the future should it be received again from a third party source.
If you have any questions concerning your rights or should you wish to exercise any of these rights please contact Maurice Schuttke at maurice@fspartners.co.uk.