Company Name: Think Global Recruitment] (‘the Company’)
Company Contact details for queries: Cramond Perry is the nominated Data Protection Officer and can be contacted on firstname.lastname@example.org or by mail at 34-36 Rose Street North Lane, Edinburgh, EH 2 2NP or by Phone on 0131-260-5850
Topic: Data protection & Data Processing of CV and Contact Information
Date: 1st May 2018
The Company is a recruitment business which provides job seeking services to its clients and Candidates. The Company must process 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 job-seeking 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 typically will comprise your CV, your contact details (to communicate and arrange interviews), verification of your qualifications (a legal and visa requirement), identity by passport or similar (a legal and right to work/visa requirement), references (to support applications and assess suitability for the role), appraisals (to support applications and assess suitability for the role) and will process such personal data for the purposes of providing you with job-seeking 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 and developing and managing our services and relationship with you and our clients.
The legal bases we rely upon to offer these services to you are:
- Your consent granted when registering with us via our website or job board or by phone or by signing a consent form.
- Our legitimate interests which are: to try and find you a job, to keep you updated on current job opportunities (1-2 times per month approx.), to keep our database up-to-date
- To comply with a legal or contractual obligation that we have with either you or our clients
- To fulfil an agreed obligation that we have with you
- To verify your qualification or identity
In reality, if we are unable to process your data and obtain this information it is unlikely that we will be able to introduce or supply a Candidate to a client.
b. Recipient/s of data
The Company will process your personal data with the following recipients:
- Potential employer organisations only (we will endeavour to ensure that our clients are also compliant with GDPR wherever possible).
- We do not provide any of your data to any government organisations
- Please be assured that we do not ever sell information on our database to any 3rd parties.
2. Overseas Transfers
Our job-seeking services are global in nature and both in and out with the EU.
If you are seeking work outside the EU you should be aware that Employers outside the EU may not be GDPR compliant and that given the size of the clients we work with the are unlikely to be giving an express consent to be GDPR compliant to consider you for a new position. We will endeavour to ensure that they have a compliant data protection policy.
3. 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. At present our retention policy is to retain the data for six years which is in line with tax legislation to keep auditable accounting records for HMRC in the UK.
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 not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
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.
5. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact the Data Protection Officer. The ICO is the body that governs data protection in the UK.