Company Name: Appointments Personnel (‘The Company’)
Company Contact Details: Emma Bonfiglio, Managing Director
Telephone: 01782 338787
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.
At all times we will comply with current data protection laws.
- Collection and use of personal data
- Purpose of processing and legal basis
- Legitimate interest
- Statutory/contractual requirement
- Recipients of data
- Information to be provided when data is not collected directly from the data subject
- Categories of data
- Sources of data
- Data retention
- Your rights
- Automated decision making
- Login files
- Links to external sites
- Sale of the business
- Data security
- Changes to this privacy statement
- Complaints or queries
1. Collection and use of personal data
- Purpose of processing and legal basis
Candidate: 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.
Client: We may collect information from our clients such as company name, address and telephone number, contact information for the person dealing with recruitment and/or accounts, job specifications/descriptions you provide, bank account details and invoices for temporary and permanent staff that we have supplied to you.
Supplier: We may collect information such as company name, address and bank account details should we need to pay for a service. We use your personal data to ensure we can contact you and for contractual obligations.
If you have opted-in, we may also send you marketing information and news via email/ text. You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.
In some instances we will be able to rely on soft opt-in consent to send you marketing materials (provided that we deem that it is in our legitimate interest to do so). We are allowed to market products or services to you which are related to the recruitment services we provide to you as long as you do not actively opt-out of these communications. In all other cases, we will obtain your opt-in consent.
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:
- Your consent
- 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
- 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 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
- We have our own obligations under the law, which it is a legitimate interest of ours to insist on meeting! If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.
- If you are looking for employment/have posted your professional CV information on a job board or professional networking site, we would assume that you are happy for us to collect and otherwise use your personal data to offer our recruitment services to you and to assess your skills against our vacancies
- We want to provide you with job recommendations to suit your skills and experience and relevant articles to read to help you whilst you are searching for your new job. We therefore think it's reasonable for us to process your data to make sure that we send you the most appropriate content.
- To help you with your job roles and find suitable candidates
- Managing our database and keeping company records up to date
- Giving you information about similar products of services that you have used from us recently
- If you have opted-in to our marketing emails, you may receive emails from time to time (you have the option to opt-out at any time). This service will be used to market our full range of recruitment services, send you details of surveys, reports, offers, networking events and general information about the industry sectors we think will be of interest to you.
- To store your details on our database so that we can contact you should we require services you offer
- To offer services to you or obtain a service or support from you
- To collect and use information necessary to improve your experience when you use our website, including when and how often you visit our website.
- 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.
- 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 candidates to)
- Candidates (whom we may introduce to a client)
- Former employers whom we may seek references from
- Other recruitment agencies in the supply chain
- Third party Service Providers
- Our IT and CRM provider
- The Recruitment and Employment Confederation
- Our legal advisors
- Government, law enforcement agencies and other regulators e.g. the Police, Home Office, HMRC and Employment Agencies Standards Inspectorate (EASI)
2. Information to be provided when data collected not from the data subject
Categories of data: The Company has collected the following personal data on you:
- Name, address, mobile number, email
- National Insurance number
- Nationality (through right to work check)
- Experience, training and qualifications
- Details of current salary, any benefits including pensions
- Referee details
- Bank account details (where applicable)
Sensitive personal data:
- Health information including whether you have a disability
- Criminal conviction
- Diversity information
Source of the personal data
The Company sources your personal data/sensitive personal data from:
- Jobs boards
- A former employer
- A referee whose details you previously provided to us
- Software providers who we use to support our services
- Accessing our company website
- Social media e.g. entering competitions
- Company name, address and telephone number
- Contact information of person dealing with recruitment and/or accounts
- Job specifications/descriptions provided to us
This information did not come from a publicly accessible source.
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. 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. 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.
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 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 firstname.lastname@example.org. 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.
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. Automated decision-making
The Company will not subject individuals to decisions based on automated processing that produce a legal effect or a similarly significant effect on the individual, except where the automated decision:
- Is necessary for the entering into or performance of a contact between the data controller and the individual
- Is authorized by law
- The individual has given their explicit consent
We may obtain data about you from cookies. These are small 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.
7. 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.
8. 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.
9. 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
10. Data Security
The Company takes every precaution to protect our users’ information.
Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) 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.
If you have any questions about the security at our website, you can email:
11. Changes to this privacy Statement
We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.
12. contact information
4 Lyme Drive, Lyme Vale Court, Parklands, Stoke-on-Trent, Staffordshire, ST4 6NW
Telephone Number: 01782 338787
General query email: email@example.com
Complaint's email: firstname.lastname@example.org
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk, 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.
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 (see below), 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 and terms of business with clients.
6 years in order to deal with any civil action in the form of contractual claim (Limitation Act 1980). Please note that 6 years is not a minimum legal requirement but is the time period in which a contractual claim can be made. You will still have to establish why it is necessary to keep these records.
Under data protection laws, only keep records for as long as is necessary. However, the Conduct Regulations require references to be kept for 1 year following the introduction or supply of a work-seeker to a client.
Records held relating to right to work in the UK.
2 years after employment or engagement has ended – must not be alterable.
National Minimum Wage documentation:
•Total pay by the worker and the hours worked by the worker
• Any deduction or payment of accommodation;
• Any absences eg rest breaks, sick leave, holiday;
• Any travel or training during working hours and its length;
• Total number of hours in a pay reference period
For HMRC purposes: 3 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.
Records can be kept in a flexible manner which best suits your business but should be kept for payroll purposes (see below).
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 should be kept for 4 years.
Company Name: Appointments Personnel
Address: 4 Lyme Drive
Lyme Vale Court
Stoke on Trent
To request any changes (including erasure) of your personal data, please contact:
Name: Emma Bonfiglio
Job Title: Managing Director
Telephone Number: 01782 338787
Email Address: email@example.com
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