The Company is an employment agency which provides work-finding services to its clients and work-seekers. The Company must process personal data (which may include 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 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
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, 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 are:
- Necessary on the basis of our Legitimate Interests
- Necessary for the Performance of Contract
- Necessary for Compliance with a Legal Obligation
(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 include the following:
- Managing our database and keeping work-seeker records up to date;
- Providing work-finding services to you and our clients;
- Giving you information about similar services that you have used from us recently
(c) LEGAL / CONTRACTUAL REQUIREMENT
The Company has certain legal and contractual requirements to collect personal data. For example, to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, the Company must undertake various checks including your identity and suitability for job roles. 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 the personal data we need to collect, we may not be able to continue to provide work-finding services to you.
(d) SENSITIVE PERSONAL DATA AND CRIMINAL CONVICTIONS/OFFENCES
- Personal data that reveals racial or ethnic origin is processed on the basis that it is necessary for the purpose of compliance with the Equality Act 2010 / Equal Opportunities Monitoring;
- Personal data concerning health is processed on the basis that it is necessary for:
- the assessment of the working capacity of the data subject;
- compliance with employment law including health and safety legislation
- Personal data concerning criminal convictions and offences is processed on the basis that we are legally required to undertake suitability checks, including enhanced level DBS checks, for certain roles we recruit for.
(e) RECIPIENT/S OF DATA
The Company may process your personal data and/or sensitive personal data with the following recipients:
- Potential employers and other organisations to increase your chances of finding employment;
- Third parties who carry out audits to ensure we run our business correctly;
- Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors, insurers and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
- Individuals and organisations who hold information related to your reference or application, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
- Public information sources and other third-party organisations we use to carry out suitability checks on work-seekers e.g. Companies House, the Disclosure and Barring Service (DBS), DVLA, credit reference agencies;
- Government, law-enforcement agencies and other regulators e.g. the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI).
2. INFORMATION COLLECTED
The personal data we collect or receive may include the following, as applicable:
Personal data
- Full name (including aliases)
- Date of birth
- Contact details (including telephone number, email address and postal address)
- Nationality
- Experience, training, qualifications, professional registrations (e.g. NMC pin)
- CV / employment history
- Previous employment / study references and verification of gaps in employment
- Driving licence details
- Details of referral
- Information related to your interests and preferences regarding future employment
- Additional information that you choose to tell us, whether in a CV, accompanying correspondence, or in any form you complete.
- Technical information data about your use of our website (e.g. IP address, login information, browser type, time zone setting, operating system and how you navigated our website)
Sensitive personal data
- Diversity information (including gender, racial or ethnic origin, religious or other beliefs, physical or mental health, details of any disabilities)
- Health and medical information
- Criminal record and offence data
Source of the personal data:
The Company may have sourced your personal data from third party sources including:
- Job Boards (e.g. CV Library, Indeed, LinkedIn)
- A former employer
- A referee whose details you previously provided to us
- Cookies – see below
3. DATA RETENTION
The Company will delete all non-legally required personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for two years. After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
Certain laws may require us to keep certain data for longer periods of time.
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.
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. COOKIES
Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
6. LINKS TO EXTERNAL WEBSITES
The Company’s website may contains links to other external websites. Please be aware that the Company 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 Company’s website.
7. SALE OF BUSINESS
If the Company’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.
8. DATA SECURITY
The Company takes every precaution to protect our users’ information, including:
- Only storing your personal data on our secure server and third-party systems that meet our security recommendations;
- Anti-virus / malware / spyware and firewall protection is in place and regularly updated to minimise the risk of unauthorised access to our systems;
- Email, calendars, contracts & tasks processed through Office 365 software;
- All staff accounts are password protected and all mobile devices (company registered laptops and mobile phones) are encrypted;
- All our files are securely backed up to the Cloud;
- Our staff receive regular data security awareness training
- Paper records are kept to a minimum and stored in locked filing cabinets on our secure office premises.
Only employees who need the information to perform a specific job (for example, our Consultants, Compliance and Payroll staff) are granted access to your information.
The Company 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 Company 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 info@adaltarecruitment.co.uk.
9. CHANGES TO THIS PRIVACY STATEMENT
We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.
10. COMPLAINTS OR QUERIES
If you wish to complain about this privacy notice or any of the procedures set out in it, please contact our Data Protection Officer, Jonathan Payne (Managing Director). You can contact our DPO by emailing info@adaltarecruitment.co.uk.
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.