Company Name: Definitive Recruitment Limited (‘the Company’)
Company Contact details:
Definitive Recruitment Limited
Devonshire Business Centres
Cricket Field Road
Phone: 01895 457 455 | Email: firstname.lastname@example.org
Definitive Recruitment Limited - Privacy Notice
Topic: Data protection
Date: 7th June 2018
The Company is a recruitment business which provides work-finding services to its clients and work-seekers. 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 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
a. Categories of data
b. Sources of data
3. Overseas transfers
4. Data retention
5. Your rights
6. Automated decision making
8. Login files
9. Links to external sites
10. Sale of the business
11. Data security
12. Changes to this privacy statement
13. Complaints or queries
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.
If you have opted-in we may also send you marketing information and news via email/ text. You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.
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 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 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 products or services that you have used from us recently;
• Introducing you to an opportunity or service which we believe you would reasonably expect from us
c. Statutory/contractual requirement
The Company 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 Company will process your personal data and/or sensitive personal data with the following recipients:
• Clients (whom we may introduce or supply you to)
• Former or prospective employers whom we may seek from or provide references to
• Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to
• Any other recruitment agencies in the supply chain where we notify you of this obligation to carry out our services for you (i.e. Master / Neutral Vendors or 2nd tier suppliers)
• The Recruitment and Employment Confederation where necessary to fulfil our Trade Body membership obligation in order to provide you with work finder services.
• Our Legal Advisors or Insurers when necessary (for example to fulfil our service offering to you correctly and legally)
• Our IT and ATS (Applicant Tracking System) providers. Namely: Cobweb (Hosted Exchange Provider including Microsoft Office 365 Business Solutions, SKYPE (if we communicate with you via this channel and our ATS system provider Invenias (Executive and Strategic Search Software)
2. Information to be provided [when data collected not from the data subject]
Categories of data: The Company may have (where available) collected the following personal data on you:
• Name, Address, Mobile No., Email Address, Online Profile Links (for example LinkedIn where available).
• Nationality (through right to work check)
• Profile or CV
• Current Employer
• Current / Former Job Title(s)
• Notice period (where available)
• Salary expectations (where available)
Sensitive personal data (Where necessary or applicable to the services we provide to you):
• Health information, namely whether you have a disability.
• Criminal conviction
Source of the personal data: The Company possibly sourced your personal data/sensitive personal data:
• From (Reed, Jobsite, Monster, Totaljobs, CWjobs, CV Library, Indeed) Jobs boards, LinkedIn
• A Google or other browser search
• Information can sometimes also come from Social Publicly accessible Forums, Blogs or Groups
• A former employer who referred you
• A referee whose details you previously provided to us
• Software providers who we use to support our services
• Our Information comes from publicly accessible sources.
3. Overseas Transfers [Optional]
The Company will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services.
The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
In the unlikely event we are required to transfer your personal data to countries outside the European Economic area (‘EEA’) for the purposes of providing you with work finding services, we will always give you this choice and seek your explicit consent to any proposed transfer and ensure you are aware of the possible risks of such transfers take steps to ensure adequate protections are in place to ensure the security of your information.
4. Data retention
The Company 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.
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 Company has obtained your consent to process your personal or sensitive data, we will do so in line with our retention policy, a copy of which is available. Upon expiry of any said period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal or sensitive data].
5. 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.
Where you have consented to the Company processing your personal or sensitive data you have the right to withdraw that consent at any time by contacting Sam Evans | Definitive Recruitment Limited, Devonshire Business Centres, Boundary House, Cricket Field Road, Uxbridge, Middlesex. UB8 1QG | Phone: 01895 457 455 | Email: 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 Company 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 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.
6. Cookies & Log Files
You can visit our website without giving away your personal information.
Definitive uses Google Analytics and Cookies in order to improve our service, user experience and analyse how the website is used. Aside from the approximate location (IP address), information collected by Google Analytics is mostly anonymous traffic data including browser information, device information, language.
The collected information is sometimes used to provide an overview of how people are accessing and using the Definitive website. It is not used for any additional purpose, such as to profile those who access our website.
Where used and prompted, please note that in a few cases some of our website features may not function if you remove cookies from your browser.
We may 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.
Here's more detail on the cookies used on this site. We will update this information as and when we introduce new functionality to the site.
If you continue to use this site without changing your settings, we'll assume that you are happy to receive all cookies on this website. However, if you would like general information about cookies and how to disable them, please visit https://www.allaboutcookies.org. To prevent Google Analytics cookies being set, you may install the Google Analytics Opt-Out Browser Add-On.
When you visit this website we may or may not:
- Use the Facebook, Twitter, Linked In and Add This tools, those sites set a variety of cookies.
- set Google Analytics cookies to measure the number of visitors, to see how visitors navigate the site and to see which resources they access. This helps us to develop new content and to improve the way the website works;
Item : AddThis
Cookies: di | dt | loc | psc | uid | __atuvc | uit*
Purpose: Features for sharing via social media (Facebook, Twitter etc). AddThis track visitors who use any of their features. The __atuvc cookie tracks performance used to record how many times an article has been shared via AddThis.
w AddThis Privacy and Data Practices
Item: Google Analytics
Cookies: __utma | __utmb | __utmc | __utmz
Purpose: Performance: to measure and improve site quality through analysis of visitor behaviour. To determine unique visitors to the site, how long the visitor remains on the site, and used to record where a visitor came from - e.g. search engine traffic, ad campaigns and page navigation within the site.
w Cookies and Google Analytics
Purpose: To check whether the site owner / manager or visitor is logged in or out to make use of the CMS or other secure member area features.
*These cookies are provided by a third party who could change their cookies in future outside of our control. We will review this policy regularly for any such changes.
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.allaboutcookies.org.
7. 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.
8. 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.
9. Data Security
The Company takes every precaution to protect our users’ information and one of the first things we did as part of our preparation for GDPR was to perform an Audit on our security Technical and Organisational Measures.
In line with GDPR legislation, we ceased the opportunity to raise our security measures even further and upgraded our hardware to the latest (2018 model) 6th Generation Lenovo ThinkPad X1 Carbon. The X1 Carbon is a no expense spared, thorough-bred business laptop, offering Integrated Finger Print Readers and Security Hardware Encryption Chips (dTPM2.0 Enabled). All our Laptops are shut down daily and kept up to date with the latest Microsoft security patches and updates released.
We run ESET Award winning Antivirus Software Provider, Windows Firewall, Windows 10 Professional 64 Bit, Office 365 Business Solutions Suite and Hosted Exchange Service provided by Cobweb Solutions (Microsoft Gold Partner).
For our ATS (Applicant Tracking System) we opted for the Premium Version ‘Data Privacy Extension Module’ from our provider (Invenias - No1 Executive Search Software provider in the world)
Our Wi-Fi Modems operate Encrypted (Mixed WPA2/WPA-PSK) and & employ password protected access.
Only employees who need the information to perform a specific job at Definitive (for example, consultants and / or our accounts clerk) are granted access to your information.
The Company uses all reasonable efforts to safeguard your personal information. However, you should still be mindful and 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. Also, we advise you only use Private secure networks when transferring Data as opposed to widely available Public networks / Wi-Fi Hotspots.
This site contains links to other websites. We wish to inform you that Definitive is in no way responsible for the privacy policies of these websites. We would advise you to check the privacy policies of each individual website that asks for personal data.
If you have any questions about the security at our website, you can email Sam Evans | firstname.lastname@example.org
10. 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.
11. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out within it, we would encourage you in the first instance to please contact: Sam Evans | Definitive Recruitment Limited, Devonshire Business Centres, Boundary House, Cricket Field Road, Uxbridge, Middlesex. UB8 1QG | Phone: 01895 457 455 | Email: email@example.com
At Definitive we take pride in what we do, but also accept that errors can happen even with the best of planning. In many instances it is often a simple misunderstanding or miscommunication which causes the issues. At Definitive, we will always demonstrate our best efforts to diffuse a situation and would hope to fully resolve any complaint in an amicable, timely and satisfactory fashion, where we feel it is both possible and legal.
However, 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.
Equality and Diversity Statement
We treat job applicants and employees in the same way, regardless of their sex, age, race, ethnic origin, sexual orientation, religion, or any disability. We will treat individuals fairly and equally and all decisions on recruitment, selection, training, promotion and career management will be based solely on objective and job related criteria.