Privacy Notice

We are a recruitment business providing work-finding services to our clients and work-seekers. We must process personal data (including special category data) so that we can provide these recruitment services and in doing so, we act as a data controller.

You may give your personal details to us directly, such as on an application or CV or via our website, or we may collect them from another source such as a jobs board. We 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 privacy statement. We will comply with current data protection laws at all times.

Why do we process your personal data, and which legal bases do we rely on?

We will collect your personal data (which may include special categories of personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities and developing and managing our services and relationship with you and our clients.

If you have opted-in, we may also send you marketing information and news via email/text. You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.

We have certain statutory, legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, and in some circumstances safeguarding requirements). Furthermore, our clients may require this personal data, and we may need your data to enter into a contract with you. If you do not give us the personal data we need to collect in order to comply with our statutory, legal and contractual requirements, we may not be able to continue to provide work-finding services to you.

On some occasions we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:

• 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; or
• to the extent we have your consent.

We may also process your personal data where this is necessary for one of the following purposes recognised in law: preventing crime, safeguarding individuals, protecting national security, responding to emergencies, or sharing personal data to support public tasks. When we rely on this legal basis (also referred to as ‘recognised legitimate interests’), no balancing test is required, however we will ensure the processing is proportionate and documented.

Legitimate interests

This is where we have a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where we have relied on a legitimate interest to process your personal data, our legitimate interests are as follows:

• providing work-finding services to you and our clients; including sending your information to our clients where you have demonstrated an interest in doing that particular type of work but not expressly consented to us passing on your CV;
• assessing your suitability for a role; contacting you regarding potential opportunities or our recruitment services; in order to source potential opportunities or roles as part of our recruitment services;
• contacting you to seek consent where we need it;
• giving you information about similar products or services to those that you will have used from us recently;
• managing our database and keeping work-seeker records up to date;
• and/or retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
• • establishing compliance with contractual obligations with clients or suppliers;
  • addressing any query or dispute that may arise including establishing, exercising or defending any legal claims;
  • protecting our reputation;
  • maintaining a back-up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach;
  • financial reporting;
  • determining staff training and system requirements; and/or
  • complying with any applicable laws and regulations.

With which third parties may we share your personal data?

We will share your personal data and/or sensitive personal data with the following recipients:

• clients (who we may introduce or supply you to);
• other recruitment departments or agencies in the supply chain;
• your former employers who we may seek references from;
• any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us;
• auditors who are assessing compliance and processes to ensure adherence to all relevant legislation and good practice guidance; and/or
• the following third parties who need to process data on our behalf:
• • our IT and CRM provider;
  • storage service providers including cloud storage providers;
  • legal and professional advisers; and
  • government, law enforcement agencies and other regulators e.g the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI), DWP.

What personal data do we collect and use?

We may collect the following personal data about you (whether directly or indirectly from other sources):

Personal data:

• Name
• Contact details, including telephone number, email address and postal address
• Experience, training, qualifications and skills
• CV – which may include job history and educational history
• Contact details of referees
• References
• Nationality
• Salary details
• Right to work status
• Wage slips

Special categories of personal data: We may collect special category data about you, for example health, disability, gender, sexual orientation and/or religion information, if you have included any of this type of special category data in your CV.

If a client asks us to collect equal opportunities data as part of the recruitment process for their own monitoring purposes, then we may ask you to provide details of your nationality, gender, gender at birth, age, marital status, ethnic origin, sexual orientation, religion, or disability when you apply for a role. You can answer ‘Prefer not to say’ for any question and the aggregated data that we send to the client will be anonymised with all responses in our system deleted as soon as the report has been generated and sent to the client.

Communication Records and additional checks

We may store details of telephone conversations with you along with email or other written correspondence for the purposes involved in recruitment and selection, accurate record keeping and to provide you with appropriate support. We may undertake reference checks and other checks on the details you provide to us where such checks are relevant to the job role. When providing us with contact details for your referees, you must ensure they’ve agreed to this. We would advise you to keep a record of their agreement and provide them with a link to this Privacy Notice.

How do we obtain your personal data?

We may have sourced your personal data/special categories of personal data from:

• You directly (including in your CV or from registering on our website)
• Social Media such as LinkedIn
• Online jobsites such as Indeed or Reed
• A former employer
• A referee whose details you previously provided to us
• The public domain
• Recommendations from clients or candidates

Where we have obtained your personal data from a third party such as an online job board, it is our policy to advise you of the source when we first communicate with you.

Overseas Transfers

We may transfer your personal data to countries outside the United Kingdom (UK) and the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will only do this if the client and the job role are based outside the UK or the EEA and we will ask for your informed, written consent before making such transfers. We will also take steps to ensure adequate protections are in place to ensure the security of your information which may include additional written safeguards. Please note that the EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. For further information on international transfers of personal data please visit the ICO website - A guide to international transfers | ICO.

How long do you keep my personal data?

We will retain your personal data for 4 years after the date on which we last provide you with work-finding services. Upon expiry of that period, we will contact you to ask whether you would still like us to provide work finding services to you. If you no longer want us to provide these services to you then we will cease to process your personal data and special category data. Your personal data will be securely destroyed at the expiry of the retention period.

What rights do I have in relation to my personal data?

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

• the right to be informed about the personal data we process about you;
• the right of access to the personal data we process about 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.

Where you have consented to the Company processing your personal data and special category data, you have the right to withdraw that consent at any time by contacting infocompliance@warwick.ac.uk. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where we will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.

If you believe that any of your data that we process 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.

You can contact us by emailing infocompliance@warwick.ac.uk if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of your other rights listed above.

Links to external websites

Our website may contain links to other external websites. Please be aware that we are not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by or via our website.

Data Security

We keep your personal data secure at all times using both physical and technical measures. Where appropriate, we also take measures such as anonymisation to ensure data cannot be used to identify you and/or encryption to ensure that the data cannot be accessed without the right security accesses and codes. Where we engage a third party to process personal data we will do so on the basis of a written contract which conforms to the security requirement of the UK GDPR and DPA 2018. We take measures to enable data to be restored and accessed in a timely manner in the event of a physical or technical incident. We also ensure that we have appropriate processes in place to test the effectiveness of our security measures.

We use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/the Internet. If you share a device with others, we recommend that you do not select the “remember my details” function when that option is offered.

Queries and complaints

If you wish to find out more about this privacy notice or any of the procedures set out in it please contact infocompliance@warwick.ac.uk or write to:

Data Protection Officer
Legal and Compliance Services
University of Warwick
University House
Coventry
CV4 8UW

You also have the right to lodge a complaint with the Information Commission as follows: https://ico.org.uk/make-a-complaint/.

Changes to this Privacy Notice

We will update this privacy notice from time to time. We will post any changes on the notice with revision dates. If we make any material changes, we will notify you.