ICO Registration Ref: Z7935533
Actis Recruitment (“Actis”) is a Recruitment Consultancy specialising in the Legal & IT sectors. We respect the importance of transparency, security and privacy and we are responsible for the Personal Information we process.
About this Policy
This policy sets out the basis on which any Personal Information we collect from you, or that you provide to us, will be treated. This includes what we do with it; who we disclose it to; and what controls you have.
Please read this policy carefully and if you have any questions please contact one of our privacy managers:
IT Recruitment – firstname.lastname@example.org
Legal Recruitment – email@example.com
What we do and why we collect your personal information
We collect information about you to carry out our core business and ancillary activities. We collect personal information from prospective, placed and registered candidates and potential and active clients:
- To provide you with information about job vacancies
- To provide you with recruitment services
- To send you information about some of our other recruitment opportunities
- To carry out market research and marketing analysis
The Personal Information we collect includes:
- Your identity (your full name, previous names, gender and date of birth)
- Contact details including your email, home address and phone numbers
- Your job search criteria, preferences and expectations
- Your qualifications, skills, experience and training
- Current remuneration and other benefits
- Educational history
- Employment history
- Details of employment or educational referees
- Referee contact details
- Regulatory and compliance documentation relating to your right to work and professional & educational accreditations
- Social media profiles including LinkedIn, Twitter, business Facebook or corporate website
- Professional & Career profiles or testimonies.
Information we collect about you when you visit our website
We may collect information about your computer including where available your IP address, operating system and browser type for system administration and to analyse visitor trends and traffic on our website. This information is collected in aggregate form and does not identify individuals. It is not passed on to third parties.
Collecting sensitive information
Depending on the nature of a role applied for, we may need to collect and process sensitive personal information about you, some of which may be categorised as Special Data under the GDPR. This may include information about your health (including details of any sick leave taken during your previous roles), details of any disability, details of any offences you have committed or are alleged to have committed and whether you are a member of any professional or trade associations.
You may refuse to provide any of the sensitive personal information we request, however, this may restrict our ability to provide the recruitment or other related services you have requested.
In addition, as part of our commitment to equality of opportunity and to monitor compliance with our equal opportunity policy, we may ask you to complete an equality monitoring form. Where you are asked to complete an equality monitoring form, information is provided voluntarily and on an anonymous basis for statistical analysis. It is not stored with your data records.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
- We collect your personal information so that we can provide our services to you, including to:
- Provide you with information about job vacancies and to assist you in finding a suitable position
- Maintain our business relationship, where you are a user of our website, a client or candidate
- Provide you with recruitment services - which may include career guidance
- Inform you of events, services and possible job opportunities using contact details you have provided
- Analyse visitor trends and traffic on our websites – this information does not identify you individually
- Assist in managing our relationship with you and our clients and perform administration or operational functions
- Provide you with information about other services we offer that are similar to those that you have already purchased, been provided with or enquired about
- Carry out market research, marketing analysis and satisfaction surveys.
· 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 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 rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligation. For example, we have a statutory obligation to retain employee data and placement data, including details of taxation payments.
- 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 includes 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. To support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data.
- 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.
Other Uses we will make of your data
- To notify you about changes to our service
· To ensure that content from our site is presented in the most effective manner for you and for your computer
· We will use this information to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
· To improve our site to ensure that content is presented in the most effective manner for you and for your computer; as part of our efforts to keep our site safe and secure
· To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
· To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them
- We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process.
How your personal information is collected
- Personal information may be obtained through our website (e.g. when you submit your curriculum vitae or application) or via one of our recruitment consultants when you contact them, send them your curriculum vitae or application (including via a job board), connect with them on LinkedIn or similar professional networking sites, or discuss a recruitment opportunity with them.
· Although we do not make it compulsory to give us every item of information we ask for, the more information you volunteer (and the more accurate it is), the better we can tailor our services to your needs. If the personal information we have requested is not collected, we may not be able to provide the recruitment or other related services to you.
- We may occasionally contact you with information about some of our other recruitment opportunities that we feel may be of interest to you and to invite you to update the information held by us about you.
Disclosure of your personal information
In the course of providing our services we may need to disclose your personal information to other companies (including to trusted third parties) for the purposes for which it is primarily held or for a related or secondary purpose.
We will share your personal information with:
- Selected third parties including:
- Clients for the purpose of introducing candidates to them
- Candidates for the purpose of arranging interviews and engagements
- Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you.
· We may:
- In the event of a sale, merger, liquidation, receivership or transfer of assets disclose your personal information to third parties provided that they agree only to use your personal information for the purposes that you have provided it to us
- Disclose aggregate statistics about our site visitors and candidates in order to describe our services to prospective partners, clients and other reputable third parties and for other lawful purposes – in such cases these statistics will include no personally identifying information.
- Disclose personal information, if required to do so by law, a court order or by a regulatory authority of competent jurisdiction or if we believe that such action is necessary to protect, defend or enforce the rights of Actis.
The lawful basis for the third party processing will include
- Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs
· Satisfaction of their contractual obligations to us as our data processor
· For the purpose of a contract in place or in contemplation
- To fulfil their legal obligations.
Keeping your Personal Information 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 do so
· We have put in place procedures to deal with any suspected Personal Information breaches and we will notify you and the applicable supervisory authority of a breach where we are legally required to do so.
Where we store and process your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may/will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
Unfortunately, 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. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long we retain your personal information and data
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, contractual obligations and that you are happy for us to do so. Accordingly, we have a data retention notice, which is available upon request.
We segregate our data so that we keep different types of data for different time periods. 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
- 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.
Keeping our records accurate and up to date
Your co-operation in helping us to keep your personal information accurate by informing us of any change of name, change of address or change of other contact details is an important part of this. If you would like to review or change the details you have supplied us with, you may do so at any time by notifying us in writing. If you would like to opt-out of receiving newsletters and updates from us at any time, please use the “unsubscribe” option included in the email or communication concerned.
- 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 checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at:
- 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.
The GDPR provides you with the following rights:
- 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 in certain formats, if practicable
- Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office.
- You have the right to withdraw consent at any time where we are relying on your consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Access to information
- The Act and the GDPR gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act and the GDPR once it is in force. A subject access request should be submitted to the relevant Privacy Officer. We may refuse access if it would interfere with the privacy rights of other persons or if it breaches any confidentiality that attaches to that information. To make a request to access your personal information, you will need to outline your request in writing, verify your identity and specify what information you require. Please contact the Privacy Officer with any such requests. You should anticipate that it may take time to process your application for access as there may be a need to retrieve information from storage and review it in order to determine what information is relevant
- You also have the right to ask Actis to stop using your information. However, if this involves a request for deletion of your file, please be aware that we may not be required or able to do so, particularly where your file also holds information about our clients or financial information that we need to keep for periods of up to six years i.e. that relate to tax matters. Where we are unable to comply with your request we will provide reasons.