a)  Purpose of processing and legal basis

 

The Company will collect and process personal data (which may include special categories of personal data such as health information, diversity data or criminal conviction data where appropriate and permitted by law), including information submitted via forms and uploads on our website. We 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. 

 

This also includes communicating with clients and prospective clients in relation to recruitment services, responding to enquiries, and maintaining business relationships.

 

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. 

 

On some occasions 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:

 

• 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 to those that you will have used from us recently; 

• Managing our database and keeping work-seeker records up to date; 

• Managing relationships with clients and prospective clients, including contacting business contacts in relation to recruitment services and business development;

 

​

 

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 require this personal data, and 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 in order to comply with our statutory and legal requirements, 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 (who we may introduce or supply you to)

• Your former employers who we may seek references from

• Payroll service providers who manage payroll on our behalf or other payment intermediaries who we may introduce you to 

• Other recruitment agencies in the supply chain

• Auditors who are assessing the compliance and processes of the business to ensure its adherence to all relevant legislation and good practice guidance

• Customer relationship management (CRM) systems, applicant tracking systems (ATS), email and communication platforms, and secure cloud hosting providers used to support our recruitment and business operations

• Individuals who have referred you to us, where we confirm to them that a referral was successful

 

All third parties are required to respect the security of your personal data and to process it in accordance with the law.

 

 

​

e)  Client and prospective client data

 

The Company also processes personal data relating to employees, representatives and contact persons of our clients and prospective clients.

 

This may include:

• Name

• Job title

• Business contact details (such as email address and telephone number)

• Records of communications and interactions

 

We use this data for:

• Communicating about our recruitment services

• Managing and maintaining client relationships

• Responding to enquiries

• Business development and marketing of relevant services

 

​​

​

Lawful basis:

​

We rely on our legitimate interests in operating and developing our recruitment business. We consider this use of data to be reasonable and expected within a business context.

 

You have the right to object to this processing at any time, particularly in relation to direct marketing communications.

 

 

​

f)  Processing of criminal conviction data

 

We may collect and process information relating to criminal convictions and offences where this is appropriate given the nature of the role and where we are legally permitted to do so.

 

This will usually be where such processing is necessary to comply with our legal obligations or where it is relevant to a particular role.

 

We will only process this data in accordance with applicable data protection laws and with appropriate safeguards in place.

​

 

g)  Referral programme
 

We operate a referral programme through which third parties may refer work-seekers to us. Where you are referred to us, we receive your name and contact details from the referrer. Our lawful basis for processing this data is legitimate interest — connecting suitable people with relevant opportunities. When we first contact you, we will tell you who referred you and how to ask us to delete your data; if you ask us not to proceed, we will delete your details.
 

Where you are the referrer, we hold your contact details to administer the referral and, where a referral is successful, to confirm this to you and arrange payment. We will not tell a referrer the reason a referral is ineligible.