Table Of Contents
2. Who we are and how to contact us
3. The data we collect about you
- Identity Data: data which identifies you, such as your first name, last name, username, job title, employer, title, date of birth, marital status, and gender;
- Contact Data: contact details including your personal and/or business email address, postal address and telephone number;
- Profile Data: data we store in connection with your profile when you register on our site, including your username and password (to access your account on our site) and (in the case of applicants) history of job applications and placements made via us, your preferences, interests, feedback and other communications with us and/or our clients;
- CV Data: information submitted as part of a job application and/or the registration process, including qualifications, experience and references and any other information contained on a CV;
- Application Data: applicant’s history of responding to job advertisements and the progress of those applications;
- Financial Data: if you are a client representative paying for our services, we may capture your personal data either peripherally or if you use personal payment details;
- Social Media Data: when you connect with us or like or follow our social media accounts we may have access to your personal data through the social media platform, including your social media handle, photograph, date of birth, location, occupation, interests and other information and content you make available via your social media accounts;
- Technical Data: electronic information which is automatically logged/stored by processing equipment, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our site;
- Usage Data: information about how you use our site and our services, including how you navigate our site and if you encounter any problems;
- Marketing and Communications Data: data which we capture when you sign up to our newsletters, including your preferences regarding receiving marketing communications from us.
4. How we collect personal data
- Direct interactions
- make an enquiry;
- register to access our site;
- subscribe to receive marketing communications;
- connect with us, follow us or ‘like’ us on social media;
- attend networking events
- submit a job application (including a CV) or job advertisement via job boards on our site.
- Third parties sites
- Automated technologies or interactions
- Other third parties and publicly available sources
- Identity, Contact and Financial Data from providers of technical.
- Social Media Data from the operators of social media platforms, including Facebook, Instagram, LinkedIn, Twitter and Google+ who are based inside and outside of the EU.
- Technical Data from the following parties:
- Analytics providers, such as Google (based outside the EU);
- Advertising networks, such as LinkedIn and Facebook;
- Search information providers such as Jobsite, CW Jobs and OpenWeb.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.
5. How and why we use personal data
- Where we have your consent to do so (further details provided in section 15 below);
- Where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
- Where it is necessary to comply with a legal or regulatory obligation that we are subject to.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To set up, manage access to, and maintain the security of, your online account for our site||Identity, Contact, Profile, Technical and Usage Data||Necessary for our legitimate interests (to conduct our business and perform our contracts with clients)
Consent – given at the time of registering an online account for our site and/or the Portal
|To provide recruitment services to clients by displaying job adverts on our site or third party job boards, which may include assisting with the processing of applications (including CVs) submitted by individuals in response to such job adverts||Identity, Contact and Profile Data (of client representatives)||Necessary for our legitimate interests (to conduct our business and perform our contracts with clients)|
|In the case of applicants, to process and manage job applications on behalf of and/or in consultation with clients||Identity, Contact, Profile and CV, Application Data and DBS checks (which will only be conducted where relevant/necessary to the role and with your prior knowledge)||
Necessary for our legitimate interests (to conduct our business and perform our contracts with clients)
Consent – we will ask you to consent to us passing on your personal data to clients at the point of submitting your application
If DBS checks are carried out, we will generally rely on the following grounds:
To manage our relationship with you which will include:
|Identity, Contact, Profile, Application, Social Media and Marketing and Communications Data||
Necessary for our legitimate interests (to conduct our business and keep our records updated)
Necessary to comply with a legal obligation
|To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity, Contact, Usage and Technical Data||
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)
Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you based upon your content preferences||Identity, Contact, Profile, Usage and Marketing and Communications Data||Necessary for our legitimate interests (to develop our services and grow our business)|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||Identity, Contact Technical and Usage Data||Necessary for our legitimate interests (to define types of customers for our services, to keep our business updated and relevant, to develop our business and to inform our marketing strategy)|
|To deal with and respond to queries submitted to us via our site, social media accounts, by post, email or by telephone||Identity, Contact, Social Media, Profile, Application and Marketing and Communications Data||
Consent – given at the time of contact
Our legitimate interests (to conduct our business and correspond with applicants and clients)
- are an applicant who has applied to one of the roles we have advertised or if we have previously hired you for a contract role;
- are an applicant who has uploaded their CV in response to a third party job board on a third party website, thereby making your CV and contact details public for recruiters and employers to contact you with job opportunities;
- are a client representative whose contact information is displayed upon your company’s website or has been provided to us by one of your colleagues;
- have consented to receive marketing and recruitment communications from us.
- clicking on the unsubscribe button in the footer of any marketing email from us or;
- contacting our Data Compliance Officer at email@example.com
7. Automated decision-making
8. Change of purpose
9. If you fail to provide personal data
11. Who we disclose personal data to
|Name of Service Provider||Platform||Types of Personal Data|
|Keybridge||IT Support Provider||Identity, Contact, Profile, CV, Application, Financial, Marketing and Communications Data|
|JXT||Website Host||Identity, Contact, CV, Profile, Application, Technical and Usage Data. This type of personal data is only shared through the website host as a processor if a data subject creates an online account with us|
|Broadbean||Data Analytic Software||Identity, Contact, CV and Application Data|
|Mercury||Recruitment Software||Identity, Contact, Profile, CV, Application, Financial, Marketing and Communications Data|
- We have entered into a data processing agreements with the service providers listed above.
- Technical and Usage Data may also be disclosed to Google Analytics, our analytics and search engine providers.
- Identity, Contact, CV, and Application Data, including as part of a job application, may be disclosed to the relevant client advertising and/or managing the relevant job advertisement. We will obtain your consent before disclosing your personal data to clients. Our clients will process applicant personal data as a data controller, and should direct applicants to their own privacy policies setting out how they process personal data.
- Identity, Contact, Profile, Usage and Marketing and Communications Data may be disclosed to Active Campaign CRM and similar agencies who provide marketing and recruitment services to us.
- Identity, Contact, CV, Application, Profile and Marketing and Communications Data may be disclosed to professional advisers (acting as processors or joint controllers) including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Companies and organisations for the purposes of fraud protection and credit risk reduction, such as Credit Safe.
- HM Revenue & Customs, regulators and other authorities (acting as processors or joint controllers) who require reporting of processing activities in certain circumstances.
12. International transfers
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
13. Data security
14. Data retention
15. Your rights in respect of your personal data
- the right to request access to your personal data that we hold and to receive certain information relating to that data;
- the right to ask us to rectify inaccurate data or to complete incomplete data;
- a right to receive or ask for your personal data to be transferred to a third party(note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you);
- the right to request the erasure of personal data where there is no good reason for us continuing to process it (note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request);
- the right to object to how we process your personal data where we believe we have a legitimate interest in processing it (as explained above) (note that in some cases we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms);
- the right to restrict processing of your personal data in certain scenarios, for example if you want us to establish the accuracy of the data or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it (note that when processing is restricted, we are allowed to retain sufficient information about you to ensure that the restriction is respected in future; and
- where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. If you withdraw your consent, we may not be able to provide certain services to you.
16. Changes to your personal data
INFORMATION ABOUT OUR COOKIES
- Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site or to submit job applications securely.
- Analytical/performance cookies. These types of cookies allow us to analyse how visitors use our site and to detect problems encountered by visitors of our site. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our site, the individual pages you have visited and the links you have followed.
|Type of cookie||Cookie name||Purpose|
|Functionality cookies||Internally verified functionality cookies provided by JXT||
These cookies enable us to identify visitors each time they visit our site.
Please note that third parties (including, for example, advertising networks and providers of external services such as web traffic analysis services) may also set cookies on our site, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You can block all cookies, and withdraw your consent to the use of analytical/performance cookies, functionality cookies and targeting cookies, at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block strictly necessary/essential cookies you may not be able to access all or certain parts of our site.
Except for strictly necessary cookies, Google Analytics cookies, all cookies will expire at the end of your browser session.