|Company Name:||SearchHigher (‘the Company’)|
|Company Contact details:||SearchHigher The Beehive University of Warwick Westwood Way Coventry CV4 8JE Telephone: 024 7652 2050 Email: firstname.lastname@example.org|
|Date:||17th January 2023|
1. Collection and use of personal data
a. Purpose of processing and legal basisThe Company will collect your personal data (which may include special category 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. In some cases 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:
Your consentWe may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if we would like to put you forward for a vacancy that you have not applied for we would ask for your consent to share your details with our client. You may withdraw your consent to our processing of your personal information for a particular purpose at any stage. Please note that we may continue to retain, or otherwise use your personal information, where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in order to comply with those interests or obligations.
To comply with a legal obligation that we haveWe must comply with a number of statutory provisions, including the Conduct of Employment Agencies and Employment Businesses Regulations 2003, when providing our recruitment services which require us to process personal data. These require us to:
- verify a candidate’s identity
- assess a candidate’s suitability for a job role
- maintain work-seeker records, including CVs and interview notes
Where we have a legitimate interestThis is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests are as follows:
- in order to provide work-finding services to you upon initial contact, following this we will obtain your consent for future contact;
- contacting you to seek consent where we need it;
- to assess your suitability and to contact you regarding potential opportunities and/or our services
- in order to source potential opportunities or roles as part of our Recruitment Services
- managing our database and keeping your records up to date
- 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
- determining staff training and system requirements
b. Statutory/contractual requirementThe Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003). Our clients may also require this personal data. If you do not give us personal data we need to collect we may not be able to continue to provide work-finding services to you.
c. Recipients of dataThe Company will process your personal data and/or special category data with the following recipients:
- Hirers and clients, necessary for the provision of our Recruitment Services
- Your former or prospective new employers that we obtain or provide references to
- Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
- Parties who process data on our behalf to include:
- IT support
- Storage service providers including cloud
- Legal and professional advisers
d. Communication recordsThe Company 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. The Company will undertake reference checks and may undertake 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.
2. This section applies when we have not collected your personal data directly from you
Categories of dataThe Company has collected the following personal data on you: Personal data:
- 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
Source of the personal data:The Company may have sourced your personal data/special category data from:
- Social Media such as LinkedIn
- Online jobsites such as Reed
- The public domain
- Recommendations from clients or candidates
3. Overseas Transfers
The Company may transfer only the information you provide to us 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 consent before making such transfers.
We will take steps to ensure adequate protections are in place to ensure the security of your information which may include safeguards. Where there are no safeguards in place there may be a risk that there is a lower level of protection in the destination country which may impact on your ability to exercise your data protection rights, in particular to protect yourself from unlawful use or disclosure of your personal data. In this instance there are no safeguards in place.
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’s pages.
4. Data retentionThe Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. For example, 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 personal data, we will retain your data for 2 years in line with our retention policy which can be found by viewing Warwick’s records management page and selecting the University’s Record Retention Schedule (RRS), which is kept up to date separately. 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. Your personal data will be securely destroyed at the expiry of any relevant retention period.
5. Your rightsPlease be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you;
- The right of access to the personal data the Company processes on 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.
6. Data SecurityThe Company keeps 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 the Company engages a third party to process personal data it will do so on the basis of a written contract which conforms to the security requirement of the GDPR and DPA 2018. The Company takes measures to enable data to be restored and accessed in a timely manner in the event of a physical or technical incident. The Company also ensures that we have appropriate processes in place to test the effectiveness of our security measures.
7. Complaints or queriesIf you wish to complain about this privacy notice or any of the procedures set out in it please contact email@example.com or write to:
Data Protection Officer,
Legal and Compliance Services,
University of Warwick,
Coventry CV4 8UW
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.