We are Refreshing Recruitment Ltd of Hunthay House, Axminster, Devon EX13 5RJ, and are a “data controller” within the definition of the General Data Protection Regulations (“GDPR”). This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this Privacy Notice.
We take very seriously the protection of personal information. We will comply with data protection law as amended from time to time. This legislation says that the personal information we hold about you must be:
- used lawfully, fairly and in a transparent way.
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- relevant to the purposes we have told you about and limited only to those purposes.
- accurate and kept up to date.
- kept only as long as necessary for the purposes we have told you about.
- kept securely.
We may change this Policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. By continuing to provide us with your personal data, or continuing to use our Services, you continue to agree to our processing your personal data in accordance with this policy as amended from time to time. This version of our Policy is effective from [1 April 2018].
Your Agreement to our Processing of your Data
By submitting your personal data and any job application to us, you
- agree that any information that you provide is accurate, complete and true to the best of your knowledge and understand that any deliberate omission or inaccurate statement could lead to your application being rejected or your dismissal;
- authorise us and our Client to verify or have verified on our behalf all statements contained in your application and to make and receive reference checks (if relevant).
What We Collect
Personal data is collected to facilitate the recruitment process and used for anonymised reporting purposes.
- personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
- date of birth;
- marital status and dependants (if you tell us about this);
- next of kin and emergency contact information;
- National Insurance number;
- bank account details, payroll records and tax status information;
- current salary and other benefits information such as annual leave entitlement and pensions (if you tell us about this);
- recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
- employment records (including job titles, work history, working hours, training records and professional memberships)
We may also collect, store and use the following “special categories” of more sensitive personal information but only if you have provided us with this information;
- information about your race or ethnicity, religious beliefs, sexual orientation and political opinions:
- Trade Union membership;
- information about your health, including any medical condition, health and sickness records.
If you don’t want us to process this information, please do not provide this to us.
How We Collect Your Personal Information
We collect personal information about candidates, employees, workers and contactors through the application and recruitment process. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.
How We Will Use Information About You
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- where we need to perform the contract we have entered into with you.
- where we need to comply with a legal obligation.
- 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.
We may also use your personal information in the following situations, which are likely to be rare:
- where we need to protect your interests (or someone else’s interests); or
- where it is needed in the public interest (or for official purposes).
Situations in which we will use your personal information
We will use your personal information primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
- to provide you with recruitment services including processing your application in respect to a particular role for which you have applied, or to process your application to match you to other suitable roles;
- checking you are legally entitled to work in the UK;
- administering the contract we have entered into with you;
- equal opportunities monitoring;
- internal record keeping.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information. If you fail to provide certain information when requested, we may not be able to provide you with recruitment services.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We do not envisage that we will hold information about criminal convictions, unless you expressly provide us with this information in your application or related documents. We request that you do not provide us with this is category of information unless it is directly relevant to the job for which you have applied and if we have expressly asked you for such information.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
Do We Need Your Consent?
Sharing your personal information with third parties?
We will share your personal information with third parties such as prospective employers so that we may provide you with the recruitment services or where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. We may contact any third party referees for a reference where you have provided us with details of those referees. We will only contact referees where you are in the final stages of any recruitment process and then only with your agreement. We require third parties to respect the security of your data and to treat it in accordance with the law.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will retain limited personal data on our candidate database for the purpose of providing you with additional recruitment services, unless you have asked us to remove you from our database.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Rights Of Access, Correction, Erasure, And Restriction
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. We might not be able to provide you with our services if you do not provide us with up to date information.
Under certain circumstances, by law you have the right to:
- request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Director in writing.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right To Withdraw Consent
In the limited circumstances where you may 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. To withdraw your consent, please contact Dan Brett on Dan@Refreshingrecruitment.co.uk. 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.
We have appointed a Data Protection Director to oversee compliance with this Privacy Notice. If you have any questions about this Privacy Notice or how we handle your personal information, please contact Dan@Refreshingrecruitment.co.uk. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.