Global Jobs Network (‘the Firm’)
Firm Contact details:
Gordon Nuttall, Senior Partner, firstname.lastname@example.org
Privacy Notice (including for use on the Firm website)
28th May 2018
The Firm is a recruitment business which provides work-finding services to its clients and candidates. The Firm must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Firm acts as a data controller.
You may give your personal details to the Firm 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 Firm 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
3. Overseas transfers
4. Data retention
5. Your rights
7. Login files
8. Links to external sites
9. Sale of the business
10. Data security
11. Changes to this privacy statement
12. Complaints or queries
a. Purpose of processing and legal basis
The Firm 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.
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 Firm 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 Firm 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;
· Providing work-finding services to you and our clients;
· Contacting you to seek your consent where we need it;
· Giving you information about similar services that you have used from us recently.
c. Statutory/contractual requirement
The Firm 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 Firm will process your personal data and/or sensitive personal data with the following recipients:
· Clients (whom we may introduce you to)
· Former or prospective new employers whom we may seek references from/provide references to
· Other recruitment agencies in the supply chain
· The Recruitment and Employment Confederation for the purposes of internal audit
· Our third party professional advisors such as IT consultants responsible for maintaining and delivering our systems. Any such access is solely to enable delivery of the relevant business services provided by such advisors to the Firm.
· Any third-party organisations used to carry out suitability checks on work-seekers e.g. Companies House, the Disclosure and Barring Service (DBS),
· Government, law enforcement agencies and other regulators , where we are permitted and requested to do so by law
· Any other organisations you ask us to share your data with.
· We may share aggregated demographic information with our clients or other third parties. This is not linked to any personal information that can identify any individual person.
· If the Firm is sold or integrated with another business your details may be disclosed to our advisors and any prospective purchaser and their advisers and will be passed on to the new owners of the business.
The Firm 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. 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.
Where applicable 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 3 to 6 years.
Where the Firm has obtained your consent to process your personal and, where applicable to job role, sensitive personal data, we will do so in line with our retention practice.
This is to retain your data on file for 5 years since we were last in contact with you in relation to relevant work-finding services. Upon expiry of that period the Company will cease to process your personal data and sensitive personal data.
An annual review of our database is carried out to identify the records of any candidates who we have not been in contact with in the preceding 5 years.
Upon expiration of this 5-year retention period, the personal data shall be deleted, unless such retention is necessary for our legitimate business interests, compliance with a legal obligation to which we are subject, or in order to protect the data subject’s vital interests or the vital interests of another natural person.
Where the personal data is stored in paper form, it will be disposed of using our confidential waste system. Electronically stored information shall, where possible, be permanently deleted from both our live system and our back up- system.
Please be aware that you have the following data protection rights:
· The right to be informed about the personal data the Firm processes on you;
· The right of access to the personal data the Firm 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 Firm processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting Gordon Nuttall, Senior Partner, via email@example.com. Please note that if you withdraw your consent to further processing that 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 Firm 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 Firm 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.
We may obtain data about you from cookies. These are small text files that ask permission to be placed on your computer's hard drive by websites that you visit. Once you agree, theyare placed on your computer until they expire. 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 can also enable more personalised content to be delivered. The cookies we set contain no personal information.
The cookies we use and why are set out below:
· PHPSESSID - This cookie is a reference to a unique session ID set by our website for the current browsing session. No personal data is stored in it. The session is ended when a user’s browser is closed. This enables core site functionality.
· Share This - The "__unam" cookie is set as part of the ShareThis service and monitors "click-stream" activity, e.g. web pages viewed, navigation from page to page, time spent on each page etc. The ShareThis service only personally identifies you if you have separately signed up with ShareThis for a ShareThis account and given them your consent.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org. Please note that in a few cases some of our website features may not function if you remove cookies from your browser.
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.
The Firm’s website may contains links to other external websites. Please be aware that the Firm 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 Firm’s website.
If the Firm’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.
The Firm employs reasonable and appropriate security measures to protect against the loss, misuse, and alteration of the personal information it processes. Our recruitment database uses Transport Layer Security. (TSL) technology protects information using both server authentication and data encryption to help provide that personal information is safe, and secure while in transit. The database also implements an advanced security method based on dynamic data and encoded session identifications and hosts the Service in a secure server environment that uses a firewall and other advanced technology to protect against interference or access from outside intruders. Finally, our database provides individual usernames and passwords that must be entered each time we log on. These safeguards help protect against unauthorized access, maintain data accuracy, and provide for the appropriate use of personal information.
Our web servers are protected by tightly controlled firewalls and are safeguarded by intrusion detection technology. They are cloud based and housed within a security data facility with multiple failover systems.
Only employees who need the information to perform a specific job are granted access to your information.
The Firm 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 Firm 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 Gordon Nuttall senior partner via firstname.lastname@example.org.
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Gordon Nuttall Senior Partner via email@example.com.
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.