Your privacy is important to us and we take it very seriously. The policy below lays out how People First (Recruitment) Ltd handles your personal data in line with The General Data Protection Regulation (GDPR). Our aim is to be responsible, relevant and secure when using your data. People First relies on your Personal Data to provide effective work-finding services to you; hence you should ensure that the Personal Data you provide is accurate, correct and complete. If you wish to correct, update or delete your Personal data, please contact us.
Please take a moment to read through what information we collect about you, with whom we may share it and how it might be used.
WHO CONTROLS MY PERSONAL DATA?
- The Data Controller is People First (Recruitment) Ltd, registered in the UK, company number 3411568
- The registered address is 6th Floor, 11 Ironmonger Lane, London. EC2V 8EY.
- You can contact People First by email (firstname.lastname@example.org,attention of the Managing Director)
- You can contact us by post at the address above (attention of the Managing Director)
- You can call us on 020 7796 3636
- People First (Recruitment) ltd is registered as a Data Controller with the Information Commissioner's Office Certificate number z6822796
WHAT DATA WILL THE CONTROLLER COLLECT AND FOR WHAT PURPOSE?
During the course of our relationship with you, we will collect personal data about you, such as the following:
- Personal details, such as your name, contact details, date of birth, gender, bank details and national insurance number;
- Details about your background, including CV, employment history, education, qualifications, right to work documents (passport/visa) and references;
- Personal Data may also include a link to a professional profile including a photograph if one is available in the public domain e.g. LinkedIn, Twitter, Business Facebook or Corporate Website;
- Information from social media activity when you interact with us on social media;
- Additional information which may help us to understand how to improve our service to you;
- We may also collect sensitive personal data (eg. about your racial origin, health) which you may choose to provide us with voluntarily from time to time.
The personal data will be stored, processed, used and disclosed by us in the following ways:-
- To respond to your queries;
- To provide our work-finding services to you and to facilitate the recruitment process;
- To match your details against job vacancies which we feel may be appropriate for you in order to assess your suitability for them;
- To enable you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
- To apply for jobs on your behalf by sending your data to clients;
- To set you up on a work assignment with a client;
- To carry out background checks which may be necessary in order for you to start work with a client;
- To fulfil our contractual obligations to you and our client, where we have entered into a contract;
- To make payments to you, manage timesheet submission, and other HR services, such as managing your statutory rights and work appraisals for our clients;
- To prepare reports for clients – for example reports on financial or administrative matters or compliance with legal requirements;
- To send you details of vacancies, networking and client events and general information about the industry sectors which we think might help you in your career search;
- To use in a brief anonymised format to appear on our website and to send as an e-shot, in order to maximise your career opportunities;
- To communicate our full range of recruitment services to you (permanent, temporary, contract and retained services);
- To enable us to improve our customer service;
- To use your information on an anonymised basis to monitor compliance with our equal opportunities policy;
- To inform you about any updates about People First which might affect you and inform you about any People First events and promotions which might help you in your career search;
- We may contact you by email, phone, SMS, post, e-communication platforms or through social media sites;
From time to time we may seek your consent to process, use or disclose your information for other purposes not listed above.
- Contact details of individuals within the organisation to enable you to provide your services to us;
- Bank details or other payment information for us to fulfil our contractual obligations with regard to payment.
During the course of our business relationship, we will collect the following:-
- Personal data of individuals within the organisation, such as name, job title, contact details, and a record of any correspondence. Personal data may also include a link to a professional profile, including a photograph if one is available in the public domain, eg. LinkedIn, Twitter etc.
The personal data will be stored, processed, used and disclosed by us in the following ways: -
- To provide our recruitment services to you and to facilitate the recruitment process;
- To send marketing materials promoting our services;
- To comply with any legal obligation or to co-operate with the police, government or regulators;
- To market our full range of recruitment services to you (permanent, temporary, contract and retained services);
- To enable us to develop and market other products and services and to improve our customer service. You may unsubscribe from our marketing communications at any time by clicking on the “unsubscribe” link, or by contacting email@example.com (attention of the Managing Director);
- To send you details of networking and client events and general information about the industry sectors which we think might be of interest to you;
- To inform you about any industry developments, or updates about People First and any of its events and promotions;
- To transmit information between our offices for internal administrative purposes;
- To fulfil our contractual obligations to you;
- We may contact you by email, phone, SMS, post, e-communication platforms or through social media sites;
- We may collect personal data on your visits to the Website including, but not limited to, your IP address, browser, timestamp, traffic data, location data, weblogs, content from surveys and contact forms and other communication data and the resources that you access;
- We will collect any information you provide to us when you use the contact forms on our website. The provision of your personal data via our contact forms is not a statutory or contractual requirement; however, please note that fields marked with an asterisk (*) are mandatory fields, because we need this information to comply with or respond to your request, or to improve your future experiences with us and our Website. Other information or personal data you share with us when completing our contact forms is at your sole discretion
- Information collected via cookies or similar technology - please see our Cookies Policy
- Your IP address
- Social media information such as your activity when you interact with us
- Information regarding any problem you report with our website
REFEREES AND EMERGENCY CONTACTS
- As part of our background screening checks, we require the contact details of a nominated referee to confirm details provided by a candidate in order to facilitate the hiring process.
- We sometimes require the personal details of an emergency contact person (name and contact details), in order to contact someone on your behalf, in case of emergency.
PASSING ON YOUR DATA TO THIRD PARTIES
From time to time, we may pass on your personal data to third parties:
- We may disclose candidate personal data to our clients or an intermediary involved in managing the supply of personnel for that client, for the purpose of providing our work-finding services, as described above. Some clients or intermediaries may require that we send data via an on-line portal which may also be managed by a 3rd party provider. We may also send your CV via email or other means.
- We may disclose candidate personal data to service providers we have retained to provide services that you or our client have requested, such as; References checking; qualifications and criminal record checking services; verification of the details you have provided; psychometric evaluation or skill test etc.
- We may disclose such information where we believe that this is required by a relevant law or regulation – for example with local tax authorities, immigration officials or for audit or other investigative purposes, including in connection with anticipated litigation.
- We may disclose such information if legally required to do so, if requested to do so by a governmental entity, or if we believe in good faith that such action is necessary to: a) conform to legal requirements or comply with legal process; b) protect the rights or property of People First; c) prevent a crime or protect national security; or d) protect the personal safety of users or the public.
- We may disclose information to third parties who perform functions on People First’s behalf, such as professional advisors, IT consultants, insurers and e-communication platform providers.
- We may disclose and transfer such information to a third party who acquires all or a substantial portion of People First’s business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets.
- Some of the 3rd parties that we disclose your data to may store, transfer or process your data outside of the UK.
HOW LONG WILL YOU HOLD MY DATA?
- Due to the niche area of recruitment in which we work, we often work with individuals over a number of years and provide our work-finding services several times to the same individual during the course of his/her career. We will retain your Personal data for the length of time required for the specific purposes for which it was collected.
- You may also request the deletion of your personal data at any point.
- The Company will retain your personal data only for as long as is necessary, but please note that different laws require us to keep different data for different periods of time.
- 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.
- In the case of temporary workers who have worked through People First, we must also keep your personal data, such as 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.
WHAT IS THE LEGAL BASIS OF THE PROCESSING?
People First relies on the following as the lawful bases for processing your personal data:-
Legitimate Interest - People First provides work-finding services to individuals and, in order to provide these services to you, we need to be able to process your data in the ways we have outlined. We undertake to balance the rights and freedoms of the individual against our legitimate interest, but it is our belief that it is also in your interest as a work-seeker that we should be able to process your data in these ways. We undertake to be clear and transparent about what we do with your data; if we intend to transfer your personally identifiable data to a third party (for example sending your named CV to one of our clients), then we will inform you beforehand.
Contractual Necessity - If we have agreed terms with you (for example as a temporary worker on a contract for services), then we will rely on Contractual Necessity as our legal basis for processing your data, as we will need to process your data, in order to fulfil our contractual obligations to you.
Legal Obligation - Where processing is necessary for us to comply with the law.
WHO WILL HAVE ACCESS TO MY DATA?
- People First (Recruitment) Ltd. All our employees and data processors that have access to, and are associated with, the processing of your personal data, are contractually obliged to respect the confidentiality of your data.
- From time to time, People First may share your personal data with third parties, as outlined above.
- Your personal data will not be shared with any third parties unconnected with the work-finding services we provide. Data will only be shared with third parties who can demonstrate a genuine need to process your data in connection with your professional capacity.
- You may opt out of receiving information from People First. If you wish to opt out, please email firstname.lastname@example.org for the attention of the Managing Director.
WILL THE DATA LEAVE THE UK?
It is rare that we are requested to transfer personal data outside the UK and this would only be for the purpose of providing work-finding services.
We are committed to keeping your personal data secure and have put in place a variety of technological and procedural measures to keep your data safe; these are reviewed on a regular basis. Information storage is on secure computers in a secure environment; hard copy information is stored in locked cabinets; and information is encrypted wherever possible. Although we will do our best to protect your data, please note that the transmission of information via the Internet is not completely secure and we cannot guarantee the security of your data transmitted to the Website or any third party; any transmission is at your own risk.
WHAT ARE MY RIGHTS?
People First (Recruitment) Ltd may confirm some or all of the following rights to each Data Subject; however this will depend on the specific legal basis (as outlined above), which applies to the processing of your own personal data:
- The right of access to a copy of the information comprised in your personal data (a Subject Access Request). To obtain a copy of the personal data we keep about you please send your Subject Access Request to the Managing Director. We will provide you with a hard copy of the personal data we keep (at no charge) within one month from receipt of the SAR. We will, however, require proof of identity.
- The right to object to processing that is likely to cause, or is causing, damage or distress.
- The right to prevent processing for Direct Marketing.
- The right to restrict or object to processing
- The right to data portability.
- The right to have inaccurate personal data rectified, blocked, erased or destroyed.
- The right to have your personal data deleted.
- The right to make a complaint to a supervisory body: In the UK, this is the ICO.
If you would like to contact People First in relation to these rights, please contact the Managing Director by post (People First (Recruitment) Ltd, 6th Floor, 11 Ironmonger Lane, London. EC2V 8EY) or email@example.com (attention of the Managing Director).