Privacy Policy
The Clements Young Ltd. (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.
Content
- Collection and use of personal data
- a.Purpose of processing and legal basis
- b.Legitimate interest
- c.Statutory/contractual requirement
- d.Recipients of data
- Information to be provided when data is not collected directly from the data subject
- a.Categories of data
- b.Sources of data
- Overseas transfers
- Data retention
- Your rights
- Automated decision making
- Cookies
- 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
a. 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.
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 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
b) 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;
Giving you information about similar products or services that you have used from us recently;
c) 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.
d) 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 you to)
Former employers whom we may seek references from
Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to
Other recruitment agencies in the supply chain
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:
Personal data:
Name, address, mobile no., email
National insurance no.
Nationality (through right to work check)
Sensitive personal data:
Health information including whether you have a disability
Criminal conviction
Source of the personal data: The Company sourced your personal data/sensitive personal data:
From jobs boards, LinkedIn
A former employer
A referee whose details you previously provided to us
Software provides who we use to support our services
Cookies listed in section 7
3. OVERSEAS TRANSFERS
The Company may transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
4. 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/specify which 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.