The Company is a recruitment and training business which provides work-finding services to its clients and work-seekers, provides candidate referral, screening and placement services and it also keeps you up to date with courses and industry/sector news. 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. This Company’s directors also operate a recruitment business as a secondary division.

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 employers, support agencies or jobs board. This information may come from application forms, letters, emails, telephone calls, text messages, written material or discussions. We as a company 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 the terms of the following statement.

1. Purpose of processing and legal basis

The Company has collected 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.

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.

The legal bases we rely upon to offer these 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

2. Categories of data

The Company has collected the following personal data on you which may include:

Personal data:

• personal details
• family details
• business activities of the person whose personal information we are processing
• lifestyle and social circumstances
• financial details
• training details
• education and employment details
• goods and services
• criminal record details
• physical or mental health details
• racial or ethnic origin
• religious or other beliefs
• trade union membership

Certain personal data, such as health information, is called “special category data” and we cannot use this without your written consent, which you can give by agreeing to the cookies notification at the bottom of the website. However, you must be aware that, if you do not give us consent to collect or store your special category data, this may limit the services we can offer you and therefore reduce their effectiveness.

3. 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 your database and keeping records up to date;
• Contacting the individual to seek your consent where you need it;
• Providing services to the individual, including sending their information to your clients where they have demonstrated an interest in doing that particular type of work but not expressly consented to you passing on their CV;
• Contacting the individual with information about similar products or services
• it is needed to access our services.
• it is required for legitimate business purposes.

4. Recipient/s of data

The Company may process your personal data and/or sensitive personal data with the following recipients:

• business associates and other professional advisers e.g. tutors & assessors
• educators and awarding bodies
• current, past or prospective employers
• family, associates and representatives of the person whose personal data we are processing
• employment and recruitment agencies
• student loan company
• suppliers and service providers;
• persons making an enquiry or complaint
• central government
• the organisation that referred you to our programme
• debt collection and tracing agencies
• the police and other law enforcement agencies

5. Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

“Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.  Our appointed data processors include:

(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: [email protected].

6. Overseas Transfers

The Company may transfer only 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.

7. 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.

We may 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.

Where the Company has obtained your consent to process your personal and/or sensitive personal data, we will do so in line with guidance and regulations.

8. 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.
• The right to make a complaint to the Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, if you think we are doing something wrong.

If you wish to exercise any of these rights, please contact the Data Protection Officer for details of how an application may be made.

There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.

9. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Victor Stephenson-Henshaw – [email protected]