Company Name: Charisma Recruitment Ltd (‘the Company’)
Company Contact details: Jenny Warner, Managing Director / Rachel Brown, Office Manager and Data Protection Officer
0207 998 8888 / 01962 813300 / firstname.lastname@example.org
Southgate Chambers, 37-39 Southgate Street, Winchester, Hampshire SO23 9EH
Document DP5 Privacy Notice
Topic: Data protection
Date: 25 April 2018
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 this privacy statement. At all times we will comply with current data protection laws.
1. Collection and use of personal data
a. What information do we collect?
Typically, we collect your current and previous employers, and details of your work, skills and experiences, education and qualifications.
We will then store pertinent details of our relationship which could include elements such as records of interviews, opportunities we have put you forward for, information you have provided to us such as a CV/supporting statement and copies of correspondence.
We may store further information where we have placed you which could include start and end dates, references and pay history.
It is unlikely we will require or process any data which would be categorised as Special under the relevant data protection legislation but should we need to do so we would contact you and get your explicit consent to do so.
b. 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.
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
c. 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.
d. Legal obligation
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.
e. Using your information to keep in touch with you
In addition to our typical processing we may use the information we hold about you in order to contact you in the following circumstances:
• To advise you of changes to our terms
• To advise you of any security concerns
• Where permitted by law
f. Recipient/s of data
The Company will process your personal data with the organisations we are working with when you are put forward for an opportunity, or where required for the fulfilment and ongoing management of a contract where we have placed you.
2. 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. 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.
Where the Company has obtained your consent to process your personal 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 data.
We are required to keep records relating to your right to work in the UK for a minimum of two years after employment or engagement has ended.
You can read out Data Retention Policy here.
3. 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 Rachel Brown, Office Manager and Data Protection Officer – 0207 998 8888 / 01962 813300 / email@example.com / Southgate Chambers, 37-39 Southgate Street, Winchester, Hampshire SO23 9EH. 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 using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
We may obtain data about you from cookies. These are small often encrypted 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. Cookies also enable us to deliver more personalised content.
The table below explains the cookies we use and why.
used to check whether your web browser is set to allow, or reject cookies
End of browser session
uses these cookies to store your authentication details, and their use is limited to the admin console area
End of browser session
uses this cookie to indicate when you’re logged in, and who you are, for most interface use
End of browser session
uses this cookie to customise your view of admin interface, and possibly also the main site interface.
Under one year from the time they’re set
Most web browsers allow some control of most cookies through the browser settings.
5. 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.
6. Links to external websites
The Company’s website may contains 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.
7. 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.
8. Data Security
The Company takes every precaution to protect our users’ information.
Only employees who need the information to perform a specific job 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 email/ 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 email/ the Internet.
If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered.
9. Changes to this privacy notice
Any changes the Company makes to our privacy notice in the future will be posted on our website – www.charismarecruitment.co.uk. Please check back frequently to see any updates or changes to our privacy notice.
10. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Rachel Brown, Office Manager and Data Protection Officer – 0207 998 8888 / 01962 813300 / firstname.lastname@example.org / Southgate Chambers, 37-39 Southgate Street, Winchester, Hampshire SO23 9EH.
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.