|Company Name:||The RecPool Group LTD (“the Company”)|
|Model Policy No.||IF13.PGP.01 “IF13”|
|Model Policy Name:||Privacy (GDPR) Policy|
Identity and contact details of the Controller
The RecPool Group Limited (“RecPool”/”we”, “us”, “our”) a company registered in England and Wales (Registration number 01633646) and whose registered address is 3rd Floor, 8 Princes Parade, Liverpool, L3 1DL is registered in the United Kingdom for the purposes UK legislation resulting from EU General Data Protection Regulations (GDPR).
Purposes for which Personal data is collected, processed, used and disclosed by us
The RecPool Group may receive or collect your personal data including but not limited to your name and contact details (i.e., address, home and mobile numbers, e-mail address), age, date of birth, details of your qualifications, experience, employment history (including job titles, remuneration and working hours) or any other relevant information from your CV, details of your referees, your nationality and immigration status and information from related documents, such as your passport or other identification and immigration documents (for example, identity card), a copy of your driving licence emergency contacts and details of any dependants, financial information, and any other relevant information. On occasions, this may also include special categories of personal data (i.e., sex and sexual orientation, religious or similar beliefs), medical information and information regarding your criminal record or security clearance for certain roles.
We may collect this information from you (for example, by filing in forms or by corresponding with us by phone, email or otherwise), your referees (details of whom you will have provided), educational provider, relevant professional body, the Disclosure and Barring Service (DBS), the Home Office, credit reference agencies or other third party who we work with, such as job boards, online CV libraries, employment businesses or agencies, umbrella companies.
This information is held, processed, used and disclosed by us as follows:
- to provide our services to you;
- to assess data about you against vacancies which we judge may be suitable for you;
- to enable you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
- to improve our customer service and to make our services more valuable to you (including tailoring our website to enrich your personal online experience);
- To enable us to develop and market other products and services and where you have consented to being contacted for such purposes;
- to answer your questions and enquiries;
- to send you details of reports, promotions, offers, networking and client events and general information about the industry sectors which we think might be of interest to you where you have consented to being contacted for such purpose;
- to provide your services to our clients;
- to send your information to clients in order to apply for assignments/vacancies or to assess your eligibility for an assignment/vacancy this includes assignments/vacancies which we think may be of interest to you in the future;
- to carry out a fair recruitment process;
- to make an informed decision to shortlist for interview and (if relevant) recruit;
- to carry out our obligations arising from any contracts entered into between you and us;
- to take steps necessary at your request prior to entering into a contract;
- To maintain records and to comply with legal, regulatory and corporate governance obligations and good employment and/or recruitment practice;
- For reasons of substantial public interest;
- to maintain our business relationship, where you are a user of our website, a client or candidate;
- to fulfil contractual obligations with our clients;
- to maintain, expand and develop our business;
- to third parties where we have retained them to provide services that we, you or our client have requested including references, qualifications and criminal reference checking services (as required), verification of the details you have provided from third party source, psychometric evaluation or skill test;
- to process data where we are legally obliged to process such data or where the processing is necessary for the purposes of carrying out our obligations or exercising our rights in the field of employment and social security and social protection law;
- We may also release personal information to third parties if we believe in good faith that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings;
- to third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, payment services, IT consultants carrying out testing and development work on our business technology systems, research and mailing houses and function co-ordinators. These third parties comply with similar undertakings of privacy and confidentiality as The RecPool Group;
- to use your information on an anonymised basis to monitor compliance with our equal opportunities policy;
- respond to and defend against legal claims;
- to notify you about changes to our service;
Legal basis for processing personal data
Our legal basis for the processing of personal data is as follows:
- for the performance of a contract to which you are party to or in order to take steps to enter into a contract;
- for the purposes of our legitimate interests or those of a third party. We have set out our legitimate interests above under the section titled “Purposes for which Personal data is collected, processed, used and disclosed by us”;
- for compliance with a legal obligation to which we are subject. This includes for the purposes of detecting crime, the collection of taxes or duties, and in order to comply with any applicable law;
- Where you give your consent to the processing of your personal data for one or more specific purposes, for example, some marketing activities we undertake. 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;
- for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
Where we provide you with work finding services, the provision of personal data is a statutory requirement and a requirement necessary to enter into a contract with us. The provision of certain category of personal data may contractually be required as instructed by our clients. You will be obliged under these circumstances to provide us with such personal data.
We may not be able to enter into a contract with you if the information is not provided to us. Where you have entered into a contract with us and you refuse to provide any information required under the contract or by law, we reserve the right to terminate our business relationship with you. Where applicable, we may refer your refusal to the relevant statutory authority requesting such information.
Where your information is held
How long we keep your data
We will only hold your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of complying with applicable legal or reporting requirements (for example, our obligations to the tax authorities or under immigration and nationality laws), our contractual obligations or our legitimate interests as a controller.
Some categories of personal data we hold will need to be retained for longer than others. 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 personal data, the purpose for which they are processed, the applicable legal requirements and our contractual obligations. Other personal data will be held for no longer than is necessary to protect our legitimate interest as a controller.
In some circumstances we may anonymise personal data so that it can no longer be associated to you, in which case we may use such information without further notice to you.
We take the security of your data seriously. We have internal policies and controls to protect your personal information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. We will update these measures as new technology becomes available, as appropriate.
We may periodically contact you by telephone, email or other digital means for marketing purposes relating to our services, our website, and/or to research opinion on proposed business developments. We will require your consent 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. You have the right to withdraw your consent if you do not want to be contacted for such purposes (see Opt-Out below).
Where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing related services, we will take your consent as given unless or until you opt out. This is referred to as soft opt-in consent and is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. In all other types of e-marketing, we are required to obtain your explicit consent.
Opt-Out – you are entitled to opt-out from receipt of marketing communication at any time and free of charge by sending an email to email@example.com.
- You may request access to the information we hold about you at any time and may request us to rectify, update or restrict processing of such information. We may ask you to verify your identity and for more information about your request. We will seek to act on your request in the timescale required by applicable data protection laws.
- We will use reasonable endeavours to ensure that your personal data is maintained and up to date. However, you are under a duty to inform us of any and all changes to your personal data to ensure that it is up to date and we will update or delete your personal data accordingly.
- You may, in certain circumstances (for example, where the personal data is no longer necessary in relation to the process for which it is collected or processed) have the right to request that we erase your personal data. We will respond to your request within the timescale required by applicable data protection laws and will only disagree with you if certain limited conditions apply. If we agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name and another identifier (for example, an e-mail address) on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
- Where we process your data on the basis of consent you have provided to us, you have the right to withdraw your consent at any time and have such data deleted. Where we are legally permitted to do so, we may refuse your request and will give you reasons for doing so.
- If practicable, we may at your request transfer your personal data to a third party controller where such personal data is processed by automated means and is processed on the basis of performing our contract with you.
- If you wish to exercise any of these rights or raise a complaint on how we have handled your personal data, you can contact us on firstname.lastname@example.org
- If you are not satisfied with our response or any of our data processing activities, you can complain to the Information Commissioners Office at:
Information Commissioner’s Office
Automated decision making
All our recruitment activities and ancillary services involve human decision making in the process.
For any other information, questions or concerns about this policy, please contact us at:
The Data Protection Officer
The RecPool Group Limited
3rd Floor, 8 Princes Parade
L3 1 DL