In line with the new General Data Protection Regulation (GDPR) all organisations which process personal data must ensure that they comply with its regulations and principles.
We must ensure that:
This Privacy Notice will detail how we comply with the above principles as well as your rights as the data owner.
1) Who are we?
Intro Recruitment Limited is a recruitment consultancy based in the North West of England. We specialise in the recruitment into the Commercial, Engineering and Industrial sectors under the name of "Intro Recruitment." Under GDPR we are defined as a "Data Controller".
2) What data do we collect?
Personal data refers to any data that can be used to identify a natural person and we only process information that we need in order assist with your job search. Depending on your relationship with us, we may collect some or all of the information detailed below (please note this list is not exhaustive):
For clients we process minimal information on you and/or employees of your organisation so that we are able to assist with any recruitment needs you may have. Types of information processed are: company address, contact number, work emails, job titles and website. We log any interaction between clients and Intro Recruitment in relation to candidates in the form of CV submits, interviews, placements and with clients & Intro Recruitment in the form of emails and telephone calls.
In order to make sure that our relationship runs without any hitches we hold a small amount of information on our suppliers. This information will be held about our contacts within your business and usually relates to name, address, contact number and emails. We will also hold your bank details so that we can pay you.
Other Information we may hold:
As mentioned above we are required to obtain referee information and act upon this information to enable you to secure your role. This information is usually name, company, job title, contact number and email.
We also hold emergency contact and next of kin information for our members of staff. If your information is provided to us for this purpose it will only be used for the nature it was given and the information provided is usually name, address, relationship, contact number and email.
3) How do we collect your data?
The majority of the data we hold is freely given by the data owner and can be provided in a number of different ways:
4) What is our Legal Basis for Processing your data?
When you provide your data, we will do our utmost to protect your information and support you in your job search. GDPR states that we are required to let you know under which legal basis your data is processed.
We are using Legitimate Interest as our legal basis for processing the following data:
Legitimate Interest - Article 6(1)(f) says:
"processing is necessary for the purpose of the legitimate interest pursued by the controller or by the third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data"
When you provide us with your CV, apply to one of our adverts or upload your CV onto a job board, it is reasonable to expect that you will be contacted by us about your job search and any potential suitable vacancies.
You may not be successful in your initial application, however, by using the information you have provided, we can let you know about any future vacancies that may be suitable for you.
We will always have an initial telephone conversation with you, so we can fully understand your career experience to date and what you are looking for, so we can provide you with a tailored service. We also inform you what you can expect from us and how your data will be used. We will arrange face to face meetings but if this is not possible, these may be completed by Skype or Facetime.
We want to ensure that we provide you with the best possible service and so we hold data on your business and the contacts within your business that we may need to have conversations with. We log details of conversations, emails sent and received, meetings, vacancies and placements.
In order to ensure prompt payment for services you have provided, we need to hold certain information on you and your business so that payments can be made.
We may hold your information if it has been provided to us as a reference for a new employee or a candidate for whom we have secured a placement.
The data noted above is necessary for our legitimate interest as a recruitment consultancy to provide a comprehensive recruitment service to our candidates, clients and new employees.
If you are a member of staff of Intro Recruitment or are working for us on a temporary contract with one of our clients, there is certain data that we require in order to process payroll - for this information we are using Legal Obligation as the legal basis for processing.
Legal Obligation - Article (6)(1) (c) says:
"processing is necessary for compliance with a legal obligation to which the controller is subject."
5) Why do we collect your data?
Our core business activity is to provide opportunities for our candidates and to support our clients to enable us to provide the best candidate to suit the business needs. In order to be able to do this we need to understand:
6) How do we use your data?
Your data is used for Recruitment and Marketing activity.
In order to be able to place the right candidate in the right job, your data may be used in one or more of the following ways:
In order to find you the best candidate, your data may be used in one or more of the following ways:
For some of the above activities your consent is required. For more information on how we obtain and manage your consent please refer to section 11 in this document.
7) Who do we share your data with?
In some circumstances we may need to share your details with a third party. This will include but is not limited to sharing data with:
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.
8) How do we safeguard your data?
Your data is of the utmost importance to us and as such we ensure relevant security is in place in order to keep your data safe and protected from any potential threats.
For more information please refer to our Data Protection Policy which is available upon request. Our contact information can be found at the end of this document.
If for any reason you believe we have not taken appropriate care of your data and it has been misused, please contact us immediately. Our contact information can be found at the end of this document.
9) How long do we keep your data for?
Please refer to our Retention & Erasure Policy which is available upon request. Our contact information can be found at the end of this document.
10) Your Rights.
GDPR provides the following rights:
There is no fee attached to this request, however, if we feel the request is unfounded or excessive, particularly if it is repetitive, we can charge a fee or refuse the request. If either of these apply we will provide you with our reasons for such action in writing.
If we have to process your data for one of the following reasons, the right to erasure does not apply:
We can only continue to process your data when the above has been resolved and we will inform you before any restriction is lifted. If your data is restricted it can only be stored if:
You have the right to transfer your details across different services. This right only applies in certain circumstances and:
When we receive a portability request we must respond within one month and no fee is applicable. We must provide the information in a structured, commonly used and machine readable format.
We must stop processing your data unless:
If your objection relates to direct marketing we must stop this immediately
If your data has been shared with a third party and you request one of your "rights" listed above, we will notify them and act upon the requirements of your request unless this is not possible or involves disproportionate effort.
If you feel we have not handled your request efficiently or are unhappy with the services we have provided in relation to the processing of your data, then you can raise your concerns with the Information Commissioners Office (ICO) https://ico.org.uk/global/contact-us/
As a business, and to comply with Article 6 of GDPR, we have agreed that the legal basis for processing your data will be (depending upon your relationship with us) either "Legitimate Interest" or "Legal Obligation". As well as complying with the GDPR in relation to direct marketing we have to comply to The Privacy and Electronic Communications Regulations (PECR).
In certain circumstances we are required to have your consent to perform certain activities. This consent can be given in the form of an opt-in or soft opt-in option. We have to ensure your consent is freely given, you understand what you are consenting to, and are able to opt-out and back in at any time.
We are permitted to market information to you in relation to the recruitment services we offer until you advise us otherwise by way of opting out.
You can opt in or out verbally during our initial registration call/meeting, using the tick box on our Registration Form or in writing to Intro Recruitment at the address below. If you are opted in and wish to opt out you can also click on the link provided in one of our marketing emails.
12) Contact Details
If you need to contact us for any reason our details are: