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 (the Candidate) 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.

Collection and use of personal data

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
• Legitimate interest
• Legal obligation
• Contractual obligation

Legitimate interest

Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

• Managing the Company’s database and keeping the candidate your work-seeker record up to date;
• Contacting the individual to seek consent when and where required;
• Providing work-finding services to including sending their information to our clients where they have demonstrated an interest in doing that particular type of work but not expressly consented to passing on their cv;
• Contacting the individual with information about similar products or services that they have used from you recently; and
• Passing work-seeker’s information to debt collection

Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following recipients:

• Clients whom the Company supply workers
• Candidates’ former or prospective new employers that you obtain or provide references to
• The Recruitment and Employment Confederation (and any other trade body that you are a member of who may have access to your candidates’ data)
• Any other third parties who carry out audits to ensure that the Company is compliant
• The Company’s insurers
• The Company’s legal advisers
• The Company’s IT and CRM providers
• Any public information sources and third party organisations that the Company may use to carry out suitability checks on work-seekers e.g. Companies House, the Disclosure and Barring Service (DBS), National College for Teaching and Leadership (NCTL), DVLA, credit reference agencies
• Government, law enforcement agencies and other regulators e.g the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI), Local Authority Designated Officers (LADOs), GLAA,
• Trade unions;

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 may result in the Company unable to source employment for you.

Recruitment businesses must collect certain personal data to meet statutory obligations, such as the Conduct of Employment Agencies and Employment Businesses Regulations 2003 – for example, they have to check identity, right to work, suitability for the role, qualifications and experience.

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 and sensitive data, we will do so in line with our retention policy. 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 and sensitive data.

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

Where you have consented to the Company processing your personal and sensitive data you have the right to withdraw that consent at any time by contacting your Recruitment Consultant, or Jo Pagdin, Managing Director/Data Protection Officer.

Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Jo Pagdin, Managing Director/Data Protection Officer.

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.

How we use cookies

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We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available here.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Record Keeping

Document type	How long to keep for (and source of requirement)
Personnel records
Work-seeker records including application form/CV, ID checks, terms of engagement (see also below), details of assignments, opt-out notices and interview notes Hirer records including client details, terms of business assignment/vacancy details.	1 year from the last date of providing work-finding services as an Employment Agency or Employment Business (Conduct of Employment Agencies and Employment Businesses Regulations 2003 (Conduct Regulations))
Terms of engagement with temporary worker	1 year from the last date of providing work-finding services as an Employment Agency or Employment Business (Conduct of Employment Agencies and Employment Businesses Regulations 2003 (Conduct Regulations))
Terms of business with clients	2 years from last date of supplying services as an Employment Agency or Employment Business in order to deal with any civil action in the form of contractual claim (Limitation Act 1980)
Working time records: 48 hour opt out notice Annual leave records	1 year from the time they were created
Annual appraisal/assessment records	1 year
References	1 year as per the Conduct Regulations
Records held relating to right to work in the UK	1 year after employment or engagement has ended
Criminal records checks/ Disclosure Barring checks	6 months
National Minimum Wage documentation: Total pay and the hours worked by the worker Overtime/shift premia; Any absences eg rest breaks, sick leave, holiday; Total number of hours in a pay reference period	For HMRC purposes: 6 years after the end of the pay reference period following the one that the records cover (National Minimum Wage Act 1998)
Sickness records – statutory sick pay	Sick pay will be on wage reports and therefore kept for 6 years
Statutory maternity, paternity, adoption pay	3 years from the end of the tax year to which it relates
Pensions auto-enrolment (including auto- enrolment date, joining date, opt in and opt out notices, contributions paid)	6 years except for opt out notices which are kept for 4 years.
Company financial records
VAT	6 years
Company accounts	6 years
Payroll information CIS records	3 years from the end of the tax year