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. 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:
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;
Retaining your data necessary for the exercise or defence of legal claims
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)
Affiliate companies: Spier Consulting, Forgerock, Transmit Security
Former employers whom we may seek references from
Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to
Other recruitment agencies in the supply chain
Agencies/employers who may seek references regarding your engagement through us, at your instigation
2. Information to be provided when data collected not from the data subject
The Company has collected the following personal data on you:
Name, address, mobile no., email
National insurance no.
Nationality (through right to work check)
Current location of work
Highest level of education
Current availability/notice period
The Company sourced your personal data:
From jobs boards: Jobserve; LinkedIn
A former employer
A referee whose details you previously provided to us
3. Overseas Transfers
The Company may 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. 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.
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/and sensitive personal data, we will do so in line with our retention policy, that this data may be processed from 6 years from when consent is obtained.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 personal data/and sensitive personal data.
Where the Company has a legitimate interest to process your personal data, we will do so in line with our retention policy, that this data may be processed from 6 years from when you last provided your data to us for the purpose of work-finding activities, or from our last engagement with you.
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 data/and sensitive personal data you have the right to withdraw that consent at any time by contacting: Dominic Garwood (the Company’s data protection representative), Moor Place, 1 Fore Street, London, EC2Y 9DT. 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 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. Automated decision-making
The Company may rely on automated profiling of applications. This will be based on various factors such as on skills, qualification, experience to determine the suitability of candidates when undertaking work finding activities.
Cookies are small data files which are stored on your computer or mobile device when you visit a website. Cookies are widely used by online service providers to facilitate and help make the interaction between websites and their visitors faster and easier, as well as to provide reporting information.
Essential website cookies: These cookies are necessary to provide you with services available through our website and to use some of its features, such as access to secure areas.
Performance and functionality cookies:These cookies are used to enhance the performance and functionality of our website but are non-essential to its use. However, without these cookies, certain functionality may become unavailable.
Analytics and customisation cookies: These cookies collect information that is used either in aggregate form to help us understand how our website is being used or how effective our marketing campaigns are, or to help us customise our website for you.
Advertising cookies:These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting ads that are based on your interests.
Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our website through third party social networking and other websites. These cookies may also be used for advertising purposes too.
You can adjust the settings on your computer to reject cookies if you wish. This is usually managed within the "settings" section of your browser.
For more information please read the advice available at aboutcookies.org
8. Log Files
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.
9. Links to external websites
The Company’s website may contain 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.
10. 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.
11. Data Security
The Company takes every precaution to protect our users’ information, including:
• Internal training of our staff in data protection best practices
• SSL, TLS & Encryption Technologies
• Restricted Access
• IT Authentication
• Anti Virus / Malware