Privacy Notice

Company Name: SSA Recruitment Ltd (‘the Company’)
Company Contact details: Hannah Hardy – DPO – hannah@ssaltd.com
Liam Byrne – Director – liam@ssaltd.com
Kieran Harte – Director – kieran@ssaltd.com
Topic: Data protection
Date: May 2018
Version: 1

The Company is a recruitment 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. 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.What personal data do we collect?

We collect the information necessary to be able to find available opportunities and further information needed to assess your eligibility. This information includes:

  • Name
  • Address
  • Telephone number
  • Email Address
  • Date of Birth
  • Education History
  • Employment History

b.Where do we collect your personal data from?

We may collect personal data about you from the following sources:

  • Directly from you. This is information you provide while searching for a new opportunity and/or during the different recruitment stages
  • From an agent/third party acting on your behalf. e.g. Interim Management Company.
  • Through publicly available sources e.g. LinkedIn, Job Boards
  • By reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer

c.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:

  • Your Consent
  • Where we have a legitimate interest
  • To comply with a legal obligation that we have
  • To fulfil a contractual obligation that we have with you

d.Legitimate interest

Where the Company has relied on a legitimate interest to process your personal data our legitimate interests are as follows:

  • To provide recruitment services to you

e.Who do we share your personal data with?

Your personal data is shared with the client who initiates the search for which you are considered, to ascertain if you are a good fit for the available position. We may also conduct checks on you to verify the information you have provided.• Your personal data is shared with the client who initiates the search for which you are considered, to ascertain if you are a good fit for the available position. We may also conduct checks on you to verify the information you have provided.

f. How and why we use your personal data

We use your personal data to match your skills, experience and education with a potential employer. We will initially collect basic information on you such as contact details, job role and experience and then pass this on to the client in search of personnel. If you are chosen by the client and go through to the next stage we will then be collecting more information from you at the interview (or equivalent) stage.

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.

Where the Company has obtained your consent to process your 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.

3. Your rights

Please be aware that you have the following data protection rights:

1.The right to be informed about the personal data the Company processes on you

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.

2.The right of access to the personal data the Company processes on you

You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy), this is so you’re aware and can check that we’re using your information in accordance with data protection law.

3.The right to rectification of your personal data

You are entitled to have your information corrected if it is inaccurate or incomplete

4.The right to erasure of your personal data in certain circumstances

Also known as ‘the right to be forgotten’ and in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

5.The right to restrict processing of your personal data

You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

6.The right to data portability in certain circumstances

You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

7.The right to object to the processing of your personal

You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).

8.The right to withdraw consent at any time

If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

Where you have consented to the Company processing your personal data you have the right to withdraw that consent at any time by contacting Hannah Hardy (DPO) and/or Liam Byrne and Kieran Harte.

There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

When requesting information on the date we hold on individuals, we are usually happy to provide this free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

  1. Baseless or excessive/repeated requests, or
  2. Further copies of the same information

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

4. Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Hannah Hardy (DPO), Liam Byrne (Director) and Kieran Harte (Director)

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://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.

Annex A

a)The lawfulness of processing conditions for personal data are:

  1. Consentof the individual for one or more specific purposes.
  2. Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract.
  3. Processing is necessary for compliance with a legal obligation that the controller is subject to.
  4. Processing is necessary to protect the vital interestsof the individual or another person.
  5. Processing is necessary for the performance of a task carried out in the public interestor in the exercise of official authority vested in the data controller.
  6. Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data, in particular where the individual is a child.

 

b) The lawfulness of processing conditions for sensitive personal data are:

  1. Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited by EU or Member State law.
  2. Processing is necessary for carrying out data controller’s obligations under employment, social security or social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental rights and interests of the individual.
  3. Processing is necessary to protect the vital interests of the individual or another individual where the individual is physically or legally incapable of giving consent.
  4. In the course of its legitimate activities, processing is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the consent of the individual.
  5. Processing relates to personal data which are manifestly made public by the individual.
  6. Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
  7. Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law which shall be proportionate to the aim pursued, respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the individual.
  8. Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional and subject to the necessary conditions and safeguards.
  9. Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy.
  10. Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.
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