For the purposes of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), the company responsible for your personal data can be found here:
Company Name: Imperative Recruitment UK Limited Trading as Imperative People, a company registered in England under number No. 04959308, whose registered office is at iCentre, Howard Way, Newport Pagnell, MK16 9PY (‘the Company’)
Company Contact details: Luke Quinn, Data Protection Officer, iCentre, Howard Way, Newport Pagnell, MK16 9PY. 01908 803403 email@example.com
Document DP5A: Privacy Notice (when personal data is obtained from the data subject)
Document DP5B: Privacy Notice (when personal data is obtained from a 3rd party, such as a job board or LinkedIn)
Topic: Data protection
Date: 23rd May 2018
The Company is a Recruitment Agency and Employment 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, advert response. 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 the terms of the following statement.
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. The legal bases we rely upon to offer these services to you are:
· Legitimate interest
· Legal obligation
· Contractual obligation
b. Categories of data
Where your personal data and/or sensitive personal data has been obtained from a 3rd Party, the Company has collected the following personal data on you:
· Date of birth
· Contact details, including telephone number, email address and postal address
· Experience, training and qualifications including qualification verification
· CV or Resume
· National insurance number
Sensitive personal data:
· ID – passport / ID – Passport Number / VISA or work permits / driving licence
· Disability/health condition relevant to the role
· Criminal conviction
c. Legitimate interest
Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
· Providing work finding services
d. Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients:
· CRM Provider – Bullhorn
· Applicant Tracking System - Broadbean
e. Statutory/contractual requirement
Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:
· we will be unable to provide you with work finding services.
2. Data retention
The Company will retain your personal data only for as long as is necessary. 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.
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.
Where the Company has obtained your consent to process your personal and sensitive 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.
In addition to the above, Consent will be requested to keep personal and sensitive date for a 2-year period and further consent will be requested after that time.
3. 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.
4. Source of the personal data
The Company sourced your personal data/sensitive personal data by the following means:
When you sent your CV direct or indirect via our website, www.imperativepeople.com or any 3rd party means such as Job Boards and Social Networking sites.
5. Complaints or Queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Luke Quinn, Data Protection Officer, iCentre, Howard Way, Newport Pagnell, MK16 9PY. 01908 803403 firstname.lastname@example.org
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at www.ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.