Introduction

 

Welcome to Recruitment Robin Ltd General Data Protection Regulations (GDPR) notice.

 

Recruitment Robin Ltd (“we“, “us” or “our“) respects your privacy and is committed to protecting your personal data. This notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your GDPR privacy rights and how the law protects you.

 

Please also use the Glossary to understand the meaning of some of the terms used in this GDPR notice.

 

Important information and who we are

 

Purpose of this GDPR notice

 

This notice aims to give you information on how Recruitment Robin Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter.

 

This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this notice

together with any other notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This notice supplements the other notices and is not intended to override them.

 

Controller

 

We are the controller and responsible for your personal data.

 

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this notice. If you have any questions about this notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

 

Contact details

 

Full name of legal entity: Recruitment Robin Ltd

 

Name or title of DPO:  Selina Rudzik

 

Email address: [email protected]

 

Postal address: Studio 1, Unit 5, Silverdale Enterprise Centre, Kents Lane, Newcastle under Lyme, Staffordshire, ST5 6SR.

 

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 (www.ico.org.uk). We would, however,
appreciate the chance to deal with your concerns before you approach the ICO so
please contact us in the first instance.

 

Processors

 

Our CRM providers, Recruit So Simple act as
our data processors and have procedures and safeguards in place to protect and
preserve personal data.  They can be contacted at 01276 300123 or [email protected]

 

In addition, Logic Melon are a data processor
that we employ to manage job applications from relevant job boards and
applications made by social media and our website.  They can be contacted
via (0) 203 553 3667 or by writing to; Silvaco Technology Centre, Compass
Point, St Ives, Cambridgeshire, PE27 5JL.

 

Changes to the notice and your duty to inform
us of changes

 

This version was last updated on 25^th May
2018.

It is important that the personal data we hold
about you is accurate and current. Please keep us informed if your personal
data changes during your relationship with us.

 

Third-party links

 

This website may include links to third-party
websites, plug-ins and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to read the
notice of every website you visit.

 

The data we collect about you

 

Personal data, or personal information, means
any information about an individual from which that person can be identified.
It does not include data where the identity has been removed (anonymous data).

 

We may collect, use, store and transfer
different kinds of personal data about you which we have grouped together as
follows:

 

• Identity Data includes first name, maiden name,
  last name, username or similar identifier, marital status, title, date of
  birth and gender.
• Contact Data includes address, email address and
  telephone numbers.
• Financial Data includes salary details.
• Profile Data includes your username and password, your
  interests, preferences, feedback, survey responses, psychometric tests and
  aptitude tests.
• Usage Data includes information about how you
  use our website and services.
• Communications Data includes your preferences in receiving
  job alerts from us.

 

We also collect, use and share Aggregated
Data such as statistical or demographic data for any purpose.
Aggregated Data may be derived from your personal data but is not considered
personal data in law as this data does not directly or
indirectly reveal your identity. For example, we may aggregate your Usage Data
to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated
Data with your personal data so that it can directly or indirectly identify
you, we treat the combined data as personal data which will be used in
accordance with this notice.

 

We may collect Special Categories of
Personal Data about you (this includes details about your race or
ethnicity, religious or philosophical beliefs, sex life, sexual orientation,
political opinions, trade union membership, information about your health and
genetic and biometric data).  We will treat these Special Categories of
Personal Data in accordance with the terms of this policy notice.

 

We do not collect any information about
criminal convictions and offences.

 

If you fail to provide personal data

 

Where we need to collect personal data by law,
or under the terms of a contract we have with you and you fail to provide that
data when requested, we may not be able to perform the contract we have or are
trying to enter into with you (for example, to provide you with services). In
this case, we may have to cancel a service you have with us but we will notify
you if this is the case at the time.

 

How is your personal data collected?

 

We use different methods to collect data from
and about you including through:

 

• Direct interactions. You may give us your Identity and
  Contact information by filling in forms or by corresponding with us by
  post, phone, email or otherwise. This includes personal data you provide
  when you:
• Contact us for the purposes of us providing
  you or the ultimate potential employer with recruitment services;
• request job alert communications to be
  sent to you; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website,
  we may automatically collect Technical Data about your equipment, browsing
  actions and patterns. We collect this personal data by using cookies, and
  other similar technologies.
• Third parties or publicly available
  sources. We may receive
  personal data about you from various third parties as set out below:
• Technical Data from the following
  parties:
  
  • analytics providers such as Google based
    outside the EU; and
  • advertising networks such as job boards
    inside the EU.
• Identity and Contact Data from other
  recruitment agencies or services with who you have registered with.
• Identity and Contact Data from publicly
  available sources such as the Electoral Register based inside the EU.

 

How we use
your personal data

 

We will only use your personal data when the
law allows us to. Most commonly, we will use your personal data in the
following circumstances:

 

• Where we need to perform the contract we
  are about to enter into or have entered into with you or with the
  potential company looking to employ you.
• 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.
• Where we need to comply with a legal or
  regulatory obligation.
•  

Generally, we do not rely on consent as a
legal basis for processing your personal data.  However, we recognize the
need for your consent and our requirement to identify to you any potential
recipient of your personal data with regard to potential employers.

 

Purposes for which we will use your personal
data

 

We have set out below, in a table format, a
description of all the ways we plan to use your personal data, and which of the
legal bases we rely on to do so. We have also identified what our legitimate
interests are where appropriate.

 

Note that we may process your personal data
for more than one lawful ground depending on the specific purpose for which we
are using your data. Please contact us if you need details about the specific
legal ground we are relying on to process your personal data where more than
one ground has been set out in the table below.

 

Purpose/Activity	Type of data	Lawful basis for processing including the basis of legitimate interest
To register you as a new candidate	(a) Identity (b) Contact	Performance of a contract with you or with the potential employer
To process your application with a potential employer to: (a) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you or with the potential employer (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you or with the potential employer (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To enable you to complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you or with the potential employer (b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about jobs that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our services and grow our business)

 

Job information from us

 

We may use your Identity, Contact, Technical,
Usage and Profile Data to form a view on what we think you may want or need, or
what may be of interest to you. This is how we decide which jobs may be relevant
to you.

 

You will receive job communications alerts
from us if you have requested information from us or if we have provided you
with recruitment services and, in each case, you have not opted out of
receiving such alerts.

 

Third-party marketing

 

We will not share your personal data with any
company outside our group companies for general marketing purposes unless we
obtain your prior consent.

 

Opting out of job alert communications

 

Where you opt out of receiving job alert
communications, this will not apply to personal data provided to us as a result
of recruitment services we have provided to you or a potential employer.

 

Change of purpose

 

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new
purpose is compatible with the original purpose, please contact us.

 

If we need to use your personal data 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
data without your knowledge or consent, in compliance with the above rules,
where this is required or permitted by law.

 

Disclosures of your personal data

 

We may have to share your personal data with
the parties set out below for the purposes set out in the table in paragraph 4
above.

 

• Internal Third Parties as set out in
  the Glossary
• External Third Parties as set out in
  the Glossary
• Third parties to whom we may choose to
  sell, transfer, or merge parts of our business or our assets.
  Alternatively, we may seek to acquire other businesses or merge with them.
  If a change happens to our business, then the new owners may use your
  personal data in the same way as set out in this notice.

 

We require all third parties to respect the
security of your personal data and to treat it in accordance with the law. We
do not allow our third-party service providers to use your personal data for
their own purposes and only permit them to process your personal data for
specified purposes and in accordance with our instructions.

 

International transfers

 

A few of our external third parties are based
outside the European Economic Area (EEA) so their processing of your
personal data will involve a transfer of data outside the EEA.

 

Whenever we transfer your personal data out of
the EEA, we ensure a similar degree of protection is afforded to it by ensuring
at least one of the following safeguards is implemented:

 

• We will only transfer your personal data
  to countries that have been deemed to provide an adequate level of
  protection for personal data by the European Commission. For further
  details, see European Commission: Adequacy of the protection of personal
  data in non-EU countries.
• Where we use certain service providers,
  we may use specific contracts approved by the European Commission which
  give personal data the same protection it has in Europe. For further
  details, see European Commission: Model contracts for the transfer of
  personal data to third countries.
• Where we use providers based in the US,
  we may transfer data to them if they are part of the Privacy Shield which
  requires them to provide similar protection to personal data shared
  between the Europe and the US. For further details, see European
  Commission: EU-US Privacy Shield.
• Please contact us if you want further
  information on the specific mechanism used by us when transferring your
  personal data out of the EEA.

 

Data
security

 

We have put in place appropriate security
measures to prevent your personal data from being accidentally lost, used or
accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents, contractors and other
third parties who have a business need to know. They will only process your
personal data on our instructions and they are subject to a duty of
confidentiality.

 

We have put in place procedures to deal with
any suspected personal data breach and will notify you and any applicable
regulator of a breach where we are legally required to do so.

 

Data retention

 

How long will you use my personal data for?

 

We will only retain your personal data 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.

 

To determine the appropriate retention period
for personal data, we consider the amount, nature, and sensitivity of the
personal data, the potential risk of harm from unauthorised use or disclosure
of your personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, and the applicable
legal requirements.

 

By law, we have to keep basic information
about our customers and candidates (including Contact, Identity, Financial and
Transaction Data) for six years after they cease being a customer or candidate
for tax and contractual purposes.

 

In some circumstances you can ask us to delete
your data: see Request erasure below for further information.

 

In some circumstances, we may anonymise your personal
data (so that it can no longer be associated with you) for research or
statistical purposes in which case we may use this information indefinitely
without further notice to you.

 

Your legal rights

 

Under certain circumstances, you have rights under
data protection laws in relation to your personal data. Further details of
these rights are set out below.

 

If you wish to exercise any of the rights set
out above, please contact us.

 

No fee usually required

 

You will not have to pay a fee to access your
personal data (or to exercise any of the other rights). However, we may charge
a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these
circumstances.

 

What we may need from you

 

We may need to request specific information
from you to help us confirm your identity and ensure your right to access your
personal data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person who has no
right to receive it.

 

We may also contact you to ask you for further
information in relation to your request to speed up our response.

 

Time limit to respond

 

We try to respond to all legitimate requests
within one month. Occasionally it may take us longer than a month if your
request is particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.

 

Glossary

 

LAWFUL BASIS

 

Legitimate Interest means the interest of our business in
conducting and managing our business to enable us to give you the best
service/product and the best and most secure experience. We make sure we
consider and balance any potential impact on you (both positive and negative)
and your rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our interests
are overridden by the impact on you (unless we have your consent or are
otherwise required or permitted to by law). You can obtain further information
about how we assess our legitimate interests against any potential impact on
you in respect of specific activities by contacting us

 

Performance of Contract means processing your data where it is
necessary for the performance of a contract to which you are a party or to take
steps at your request before entering into such a contract.

 

Comply with a legal or regulatory obligation means processing your personal data
where it is necessary for compliance with a legal or regulatory obligation that
we are subject to.

 

THIRD PARTIES

 

Internal Third Parties

 

Other companies in our group of companies and
providers of IT and system administration services.

 

External Third Parties

 

• Service providers acting as processors
  based inside and outside the EU who provide IT, system administration
  services and CV formatting.
• Professional advisers acting as
  processors or joint controllers including lawyers, bankers, auditors and
  insurers based in the EU who provide consultancy, banking, legal, insurance
  and accounting services.
• HM Revenue & Customs, regulators and
  other authorities acting as processors or joint controllers based in the
  United Kingdom.

 

Call Recording

 

We record telephone calls in and out of our
organisation for training and monitoring purposes.

 

YOUR LEGAL RIGHTS

 

You have the right to:

 

Request access to your personal data (commonly known as a
“data subject access request”). This enables you to receive a copy of the
personal data we hold about you and to check that we are lawfully processing
it.

 

Request correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you
corrected, though we may need to verify the accuracy of the new data you
provide to us.

 

Request erasure of your personal data. This enables you to ask
us to delete or remove personal data 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 data where you have successfully exercised your right to object
to processing (see below), where we may have processed your information
unlawfully or where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply with your
request of erasure for specific legal reasons which will be notified to you, if
applicable, at the time of your request.

 

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also
have the right to object where we are processing your personal data for direct
marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and
freedoms.

 

Request restriction of processing of your personal data. This enables you to ask
us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data’s accuracy; (b) where our use of the
data is unlawful but you do not want us to erase it; (c) where you need us to
hold the data even if we no longer require it as you need it to establish,
exercise or defend legal claims; or (d) you have objected to our use of your
data but we need to verify whether we have overriding legitimate grounds to use
it.

 

Request the transfer of your personal data to you or to a third
party. We will provide to you, or a third party you have chosen, your personal
data in a structured, commonly used, machine-readable format. Note that this
right only applies to automated information which you initially provided
consent for us to use or where we used the information to perform a contract
with you.

 

Withdraw consent at any time where we are relying on consent to process
your personal data. 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 products or services to you. We
will advise you if this is the case at the time you withdraw your consent.