The Company is a recruitment business which provides work-finding services to its clients and workseekers. The Company must process personal data (including 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 the terms of the following statement.
This statement provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
1. Data protection principles
We will comply with data protection law and principles, which means that your data will be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.
2. Collection and use of personal data
a. Purpose of processing
• The Company will collect, store and use your personal data (which may include “special categories” of personal data) and will process your personal data for the purposes of providing you with work finding services. We may also contact you with relevant news articles relating to your career/the legal profession. Personal data includes; Name, Date of birth, Contact details (including telephone number, email address and postal address), Experience, training and qualifications, information collected from an application form or CV, information about your current level of remuneration, including benefit entitlements, whether or not you have a disability for which the Employer needs to make reasonable adjustments during the recruitment process, information about your entitlement to work in the UK and National insurance number.
“Special categories” of personal data include:
• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
• Information about your health, including any medical condition, health and sickness records.
• Information about criminal convictions and offences.
b. How is your personal information collected?
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.
c. How we will use the information about you
As a recruitment business we will use the personal information we collect about you to provide work finding services on your behalf. We provide work finding services to both candidates and clients as part of our business. We process personal data in order to be able to provide these services – we need to assess your skills, qualifications and suitability for available roles, check your identity, your right to work, communicate with you about the recruitment process, keep records related to jobs filled, comply with legal or regulatory requirements as well as process pay. The legal basis that we rely upon to offer our services to you is legitimate interest. It is our legitimate interest to process your personal data so that we can provide you with work finding services. We will rely on consent to send you relevant news articles relating to your career/the legal profession. If you fail to provide information when requested, which is necessary for us to provide work services, we will not be able provide these services. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
d. How we use particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
e. Information about criminal convictions
We do not envisage that we will process information about criminal convictions.
f. Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
3. Recipients of Data
The Company will process your data on a computerised database (provided by Recruit So Simple) in order to provide you with work finding services. The Company will process with or transfer your personal data to their clients in order to provide you with work finding services. A list of our clients your personal data will be sent to (after obtaining your consent, if required) will be provided on request.
The Company will not process your personal data and/or sensitive personal data with any other third parties. All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal
data for specified purposes and in accordance with our instructions.
4. Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from Claire Cox. We have put in place procedures to deal with any suspected data security breach and will notify you
and any applicable regulator of a suspected breach where we are legally required to do so.
5. Data retention
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 retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy and/or applicable laws and regulations.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis. Where the Company has obtained your consent to process your personal data/sensitive personal data, we will do so in line with our Retention Policy (a copy of which is attached). 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 sensitive personal data.
6. Your rights in connection with personal information
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/sensitive personal data you have the right to withdraw that consent at any time by contacting Claire Cox.
7. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Claire Cox, Director, of Bailey Hunter Ltd at: 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.