The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
WHO WE ARE AND WHAT WE DO:
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003.
We collect information about you to carry out our business activities.
WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA:
Think Selection is registered as a data controller in the United Kingdom for the purposes of the Data Protection Act 1998 or any subsequent UK legislation resulting from EU General Data Protection Regulations (GDPR).
Our nominated Data Protection Officer is Danny Parnes, Managing Director
PURPOSE OF COLLECTING PERSONAL DATA:
We are retained by client companies to identify individuals for new employment opportunities and as such have identified you as a person that could be of interest to our clients for such employment opportunities.
INFORMATION WE COLLECT ABOUT YOU OR YOU PROVIDE TO US:
We collect information about you when you apply for our vacancies, complete forms on our website, or by corresponding with us by in person, by phone, email, social media or otherwise.
The information we collect about you or you give us may include your name, address, business and personal e-mail addresses and phone numbers, salary and salary expectations, education, qualifications, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae, photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
WHAT WE USE THIS INFORMATION FOR:
* To keep you informed of relevant opportunities that may arise
* To assist us in finding the most suitable opportunities for you and contact you to discuss those job opportunities.
• To put forward your details to our clients and prospective employers for you to be considered for vacancies;
• To keep you informed of our services, events, news and relevant information;
* To fulfil the ongoing management of a contract where we have placed or hired you.
INFORMATION WE OBTAIN FROM OTHER SOURCES:
Information we obtain about you from other sources such as LinkedIn, onlive CV libraries, job board websites and personal recommendations. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
You have the option of submitting your Curriculum Vitae to an employee of Think Selection via email or other electronic method or via our website. You can do this in order to be considered for future positions or in response to a specific employment opportunity you hear or read about. Your CV will be stored in our candidate database and will be accessible only by our recruitment consultants. You can update or remove your CV and details at any time by contacting and requesting us to do this.
LEGAL BASIS AND PURPOSES FOR THE PROCESSING:
We use information held about you in the following ways:
* The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of employment. Our service also expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs.
* To carry out our obligations arising from any contracts we have entered into or intend to enter into between you and us and to provide you with the information, products and services that you request from us or we consider will be of interest to you or relevant to your career or to your organisation.
* Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal obligations.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).
OUR LEGITIMATE BUSINESS INTERESTS:
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
We will disclose your personal information to third parties:
• Cloud based recruitment software tool
• Marketing and technology platforms
HOW LONG DO WE HOLD YOUR DATA FOR?
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. If we have not had any contact with you (or where appropriate, the company you are working for), for a period of two years we will delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it.
If we have placed you either with one of our clients, we are required by law to hold certain data for a longer period to comply with our legal obligations such as Working Time, Right To Work, Pension, National Minimum / Living Wage, Tax, National Insurance and Agency worker Regulations.
WE DO THE FOLLOWING TO TRY TO ENSURE YOUR DATA IS ACCURATE:
• prior to making an introduction we check that we have accurate information about you
The criteria we use to determine whether we should retain your personal data includes:
• the nature of the personal data;
• its perceived accuracy;
• our legal obligations;
• whether an interview or placement has been arranged; and
• our recruitment expertise and knowledge of the industry by country, sector and job role.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
WHO WILL WE SHARE YOUR PERSONAL INFORMATION WITH?
We will only make your personal information visible to 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 or hired you.
WE MAY ALSO DISCLOSE YOUR PERSONAL INFORMATION TO THIRD PARTIES:
if we use 3rd parties for running our business processes. An example of this might be that we have our emails or our database hosted in the cloud. Whilst these cloud providers would not typically have direct access to your information, storage is considered processing under the relevant data protection legislation. Similarly, as an example, if we have employed you directly we would need to send your data as required by law to local tax authorities;
if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
DATA STORAGE AND PROTECTION:
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. All information you provide to us is stored on our secure password protected systems.
All information that you provide to us, or we collect about you is stored on our secure servers. We understand that this includes confidential information and we have put in place a range of suitable physical, electronic and managerial procedures to safeguard and secure your information.
Our staff have the minimum required access to your data, and are trained to ensure that it is protected, and kept secure.
We do not store your information for longer than is necessary to provide the service, and to ensure that we have appropriate auditable records for business purposes.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by contacting us at firstname.lastname@example.org
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
You have the right to request information about the personal data we hold on you at any time. If you would like to make a request for information, please email email@example.com
CHANGES TO OUR PRIVACY NOTICE:
Any changes we make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice. If you do have any questions about our privacy commitment, please feel free to email us at firstname.lastname@example.org
We are an equal opportunity business and committed to diversity. All job applicants and members of staff will receive equal treatment and not be discriminated against on the grounds gender, marital status, race, ethnic or national origin, nationality, disability, sexual orientation, pregnancy, maternity, religion or age.
LAW AND JURISDICTION:
This privacy information notice is subject to the laws of England, and the non-exclusive jurisdiction of the English Courts. If you are domiciled in Scotland, Wales or Northern Ireland it can be enforced in your local court system.