Company Name: William James Consultants Ltd (‘the Company’)
Company Contact details: Will Bremner – email@example.com – 03301 138 832
Document DP5A/B: Privacy Notice (when personal data is obtained from the data subject/3rd Party)
Topic: Data protection
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 the terms of the following statement.
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. The legal bases we rely upon to offer these services to you are:
• Consent of the individual for one or more specific purposes.
• Processing is necessary for compliance with a legal obligation that the controller is subject to.
• Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract.
b. Legitimate interest
Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
• Establishing compliance with contractual obligations with Clients or suppliers
• Addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
• Protecting our reputation
• Maintaining a back-up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
• Evaluating quality and compliance including compliance with this Privacy Notice
• Determining staff training and system requirements
Using your personal data to:
• Assess suitability and contact you regarding potential opportunities and/or our service
• Collate market information or trends including providing analysis to potential or actual Clients
• Source potential opportunities or roles as part of our Recruitment Services
• Personalise your experience and our offering, whether via our website or otherwise
c. Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients:
• Clients of William James Consultants Ltd whom you have given consent for your data to be shared in accordance with work related services
d. Statutory/contractual requirement
Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:
• Offer of employment will be withdrawn from our client
• William James Consultants cannot assist in finding the individual new job opportunities
e. Categories of data
The Company has collected the following personal data on you:
• Name/contact details
• Email and other contact details
• Date of birth
• Educational history, qualifications & skills
• Visa and other right to work or identity information
• Bank details
• Employment history
• Contact details for referees
• Personal information relation to hobbies, interests and pastimes
• Your marketing preferences
• National Insurance and tax information (interim candidates)
2. Overseas Transfers
The Company may transfer only the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
3. 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 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.
Where the Company has obtained your consent to process your personal data, we will hold on to this for as long as necessary unless specified otherwise. Where consent is not granted the Company will cease to process your personal data.
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.
Where you have consented to the Company processing your personal data you have the right to withdraw that consent at any time by contacting Will Bremner firstname.lastname@example.org/03301138832
5. Sensitive Personal Data (SPD)
Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our consideration of your suitability for a job role. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.
Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that data for the purposes of our relationship with you or for the provision of our Recruitment Services. This will be for one or more of the following reasons:
• You have explicitly consented to the processing
• For the purpose of our assessment of your suitability for job roles or working capacity
• Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law
• To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims
6. Source of the personal data
The company sourced your personal data by the following means:
• Curriculum Vitae, application or registration form
• A Client
• Other candidates
• Online jobsites
• Marketing databases
• The public domain
• Social Media
• At interview
• Conversations on the telephone or video conferencing (which may be recorded)
• Notes following a conversation or meeting
• Our websites and software applications
7. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it, please contact: Will Bremner- email@example.com/03301138832
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.
The Company will collect the personal details that you provide to us on our website for the purposes of providing you with services and/or information. In providing such services and/or information to you we will only use your personal data in accordance with the terms of the following statement.
This statement sets out below:
1. How the Company collects your personally identifiable information through the website.
2. How the Company uses this information.
3. Who the Company may share the information with and for what purpose(s).
4. What choices are available to you regarding collection, use and distribution of your information.
5. The kind of security procedures that are in place to protect the loss, misuse or alteration of information collected through the Company’s website
6. How you can correct any inaccuracies in the information collected through the website.
Information Collection and Use
The Company collects information from our users at several different points on our website. The Company is the sole owner of the information collected on this site. We will not sell, share, or rent this information to others
We request information from you on our online registration forms. Here you must provide contact information and information regarding the type of work you are seeking and your skills, qualifications and experience. This information is used to enable us to provide you with work-finding services. If we have trouble processing your application, this contact information is used to get in touch with you.
Cookies are small text files that are placed on your computer by websites that you visit. 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.
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 or www.allaboutcookies.org.
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.
We may share aggregated demographic information with our clients. This is not linked to any personal information that can identify any individual person.
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.
This website contains links to other external websites such as our social media pages. Please be aware that the Company is not responsible for the privacy practices of such other sites. We encourage you to be aware of this when you leave our site and 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.
The Company takes every precaution to protect our users’ information.
Only employees who need the information to perform a specific job (for example, our accounts clerk or a marketing assistant) 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 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 the Internet.
If you have any questions about the security at our website, you can send an email to Will Bremner- firstname.lastname@example.org.
Correction/Updating Personal Information
If your personally identifiable information changes (such as office address), we will endeavour to provide a way to correct, update or remove the personal data provided to us. This can usually be done by emailing Will Bremner or Connor Hadden on email@example.com.
Notification of Changes
This policy was last updated January 2018.
Complaints or queries
The Company tries to meet the highest standards when collecting and using personal information. We take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
If you wish to complain about this policy or any of the procedures set out in it please contact: Will Bremner – firstname.lastname@example.org