Privacy policy
Contents
INTRODUCTION
Key Recruitment (UK) Ltd (“Key Recruitment”) respects your privacy and is committed to protecting your personal data.
This privacy notice contains information about who we are and how and why we collect, store, use and share your personal data when you interact with us.
When we collect, use, or share your personal data, we are subject to applicable data protection laws including the General Data Protection Regulation and are responsible for that personal data as a data controller. This notice will also inform you about your privacy rights and how the law protects you.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
1. IMPORTANT INFORMATION AND WHO WE ARE
Key Recruitment is a member of a group that contains different legal entities. For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), where we refer to “Key Recruitment”, “we”, “us” or “our” in this privacy notice, we reference only Key Recruitment’s obligations for processing your personal data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this Privacy notice, including any requests to exercise your legal rights, please contact our DPO using the details set out below.
If you have any questions about this privacy notice please contact us using the details set out below or via www.keyrecruitment.co.uk/contact/
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Key Recruitment |
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DPO: |
Wayne Tyson |
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Legal Entity: |
Key Recruitment (UK) Ltd |
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Address: |
Key House, 15/16 The Embankment, |
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Email: |
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Telephone: |
0161 443 0041 |
We hope that you will approach us to resolve any query or concern you might have about our use of your personal data. However, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
Changes to the Privacy Notice and Your Data
This version was published on 07/12/2018 and last updated on 07/12/2018.
We may change this privacy notice from time to time and we will inform you when those changes may affect you in a material way.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The Data We Collect About You
When you interact with us in the different ways described below, we may ask you for the following information:
Candidates
In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you, such as:
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personal and contact details (for example your name, email address, date of birth):
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personal and contact details you give us when subscribing to receive emails, newsletters or marketing information from us;
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during pre-assignment vetting we will request details from you including, your name, your work history, qualifications, contact details (such as email, telephone number and home address), your right to work documents, details required for equality and discrimination legislation checks and your personal preferences, choices and requirements specific to particular requests or services;
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details of your education, employment history, bank details and national insurance number, references, right to work and other information you tell us about yourself (e.g. the information contained within your CV) when you engage with us for the provision of services);
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information from social media activity (such as likes, shares and tweets) when you interact with us on social media;
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additional information which you provide voluntarily and/or which we may ask from you to better understand you and your interests.
We may also collect sensitive Personal Information about you (including details of your gender, physical or mental health, racial or ethnic origin, criminal allegations or offences, trade union membership and/or other sensitive Personal Information that you may choose to provide to us voluntarily or indirectly from time to time).
Supplier
We need a small amount of information from our Suppliers to ensure that things run smoothly, such as:
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contact details to enable the provision of your services to us and the fulfillment of our contract obligations, this may include names, email addresses and telephone numbers;
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bank details and any other details required to enable payment for the services supplied.
Client
If you are a client of Key Recruitment, we need to collect and use the following information:
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contact details or those of individuals at your organisation (e.g. names, telephone numbers and email addresses) to enable the provision of services and to facilitate our relationship with you, including relevant marketing.
Website Users
We collect the following data from our Website Users to improve user experience and improve service:
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information we collect via cookies or similar technology stored on your device;
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information from social media activity (such as likes, shares and tweets) when you interact with us on social media;
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information you provide if you report a problem with our website or service;
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additional information which you provide voluntarily and/or which we may ask from you to better understand you and your interests.
Referees and Emergency Contacts
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We require a referee’s contact details (name, email address and telephone number) to enable us to confirm certain details provided by the Candidate or prospective employee, to facilitate the employment process.
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Emergency contact information (a name, email address and telephone number) is required in case of an emergency where we would need to contact someone on your behalf.
3. How Is Your Personal Data Collected?
Candidates
How and when do we collect your Personal Information?
We may collect your Personal Information when you apply for a role through us (or otherwise contact us from time to time) by:
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responding to an advert on a job board or other website;
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by directly contacting our business;
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by filling in an application form in a branch;
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when you speak to one of our consultants by telephone (please see section 6 for further details); or another agency or organisation passes your details to us.
Why do we collect your Personal Information?
We collect and use your Personal Information because it is necessary to obtain certain details including Personal Information from you in the work-searching process and it is in our legitimate interests in the course of operating our business, including:
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responding to your queries;
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providing work-finding services and/or information to you;
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transmitting Personal Information between our offices or functions for internal administrative purposes;
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setting you up on a work assignment with a client;
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hosting and maintaining our websites;
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ensuring network and information security; and/or
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carrying out direct marketing.
However, we will only collect, use and handle your Personal Information when:
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it is necessary for our legitimate interests in connection with carrying out our business, as long as, in each case, these interests are in line with applicable law and your legal rights; and/or
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where you have agreed; and/or
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where this is necessary for legal obligations which apply to us.
Suppliers and Clients
How and when do we collect your Personal Information?
We may collect your Personal Information when required throughout our business relationship with you.Why do we collect your Personal Information?
We collect and use your Personal Information because it is necessary to obtain certain details including Personal Information from you to offer services to you or to obtain support and services from you:
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to perform certain legal obligations;
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in the performance of our contract with you;
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to help us to target appropriate marketing campaigns;
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in transmitting Personal Information between our offices or functions for internal administrative purposes;
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in hosting and maintaining our websites;
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in ensuring network and information security; and/or
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in carrying out direct marketing.
However, we will only collect, use and handle your Personal Information when:
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it is necessary for our legitimate interests in connection with carrying out our business, as long as, in each case, these interests are in line with applicable law and your legal rights; and/or
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where you have consented;
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in the performance of our contract with you; and/or
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it is necessary for legal obligations which apply to us.
4. How We Use Your Personal Data
Where necessary and appropriate for our business purposes and also in accordance with regulatory requirements, and where if required we have an appropriate processing agreement in place, we may use your personal data for:
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the performance of our contracts with clients and suppliers;
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third party professional advisers such as lawyers, auditors and accountants and third-party service providers and consultants performing technical services for us (such as IT support functions, testing and development work and external consultants);
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where necessary in using technology systems and document storage; and
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in using marketing services platforms.
Marketing Opt-Out – You can ask us or third parties to stop sending you marketing messages at any time by contacting us using the details set out at the start of this privacy notice. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of use of our services.
Website Cookies – You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.
CandidatesWe undertake the following processing of your Personal Information on the legal basis that it is necessary to perform the contract with you and to provide the services we have agreed to provide to you. Where we have not entered into a contract with you, we may also carry out this processing because in that pre-contractual stage where we consider it is necessary in our legitimate business interests in order to deal with requests, enquiries or comments you have made to us.
Submission of details to clients – if you register to apply for a particular role, request to be put forward for a role or if you have asked us to put you forward for suitable roles, we will share some of your personal details including your name, work history and qualifications with our clients offering potential roles which might be suitable for you.
On-boarding for a work-assignment – If you are offered and accept a work assignment through us, we will need further Personal Information from you such as NI number, bank details, emergency contact details and some medical information in order to fulfill our statutory and contractual obligations to both you and our client.
Reporting to clients and managing timesheets, payroll and work performance – We sometimes have to prepare reports for clients relating to the services provided by us for example reports on financial or administrative matters or compliance with legal requirements. Such reports may contain your Personal Information such as your name, hours worked and pay rate. In addition, we may need to manage submission of timesheets, payroll services and other Human Resourcing services such as managing your statutory rights and work appraisals for our clients, all of which would require use of your Personal Information.
Other lawfully permitted processing – We may also use any Personal Information that you provide to us for example to other companies within Key Recruitment or to employers or any other company who you ask us to approach on your behalf for work-searching purposes If you choose not to provide Personal Information requested by us, we may not be able to provide you with the services and/or information you have requested or otherwise fulfill the purpose(s) for which we have asked for the Personal Information, including placing you in a work-assignment. We will where possible anonymise or aggregate such data for reporting purposes.
Pre-Assignment vetting – We undertake Pre-Assignment vetting. We collect your Personal Information which you provide to us when applying for a role or registering for our job-finding services to comply with our (and clients’) legal obligations regarding your right to work and any necessary qualifications for roles. We may also process your Personal Information for this purpose where we consider it necessary for performance of the contract with you, or otherwise with your consent.We undertake the following processing of your Personal Information with your consent.
Marketing – Where legally permitted to do so where you have provided us with your contact details and have agreed to be contacted for marketing purposes, we may contact you by telephone or by post for marketing purposes relating to our services, our website, and/or to research opinion on proposed business developments. Your agreement to the use of your Personal Information for these purposes is optional (see Marketing Opt-out above) and if you fail to provide your agreement, your use of our work-finding services will not be affected.
5. Sharing Your Personal Data
Some services that we provide require the involvement of third parties. We have carefully selected these third parties and taken steps to ensure that your Personal Information is satisfactorily protected. Third parties may include our clients, suppliers of IT services, pay-rolling services or vetting services.
Where we employ third party companies or individuals to process Personal Information provided by us on our behalf for business functions, including (without limitation) IT support, hosting our data on cloud platforms, legal, accounting, audit, consulting and other professional service providers and providers of other services related to our business. Portions of our services may be provided by organisations with which we have a contractual relationship, including subcontractors, accordingly, your Personal Information may be disclosed to them. We only provide these organisations with the information that they need to be able to perform their services.
We will have in place an agreement with our service providers which will restrict how they are able to process your Personal Information.
We may also share your personal information where we reasonably believe that applicable law or regulation requires any personal data to be processed, for example with local tax authorities, immigration officials or for audit or other investigative purposes (including any anticipated litigation).
Sharing within Key Recruitment and to Service Providers
The Personal Information you provide to us is collected by Key Recruitment. However, where we are legally permitted to do so in accordance with this Privacy Policy, we may transfer your Personal Information between and to other functions or offices within the same corporate group for the purposes set out above.
6. INTERNATIONAL TRANSFERS
We may from time to time pass your personal data to clients outside the European Economic Area (EEA) if you have given your explicit consent for us to do so in relation to a role. No personal information is otherwise stored outside of the EEA.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes extensive IT security measures, CCTV and access to the premises monitored by an external security firm. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We will establish thereafter the extent to which the personal data has been compromised ensuring that both parties (as appropriate) can meet the requirement of notifying the supervisory authority within 72 hours.
8. DATA RETENTION
All your Personal Information is stored on-site in the UK at: The Key Group, 15/16 The Embankment, Heaton Mersey, Stockport, Cheshire, SK4 1QL.
Candidates / Clients
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. If no meaningful two-way contact has been established for 2 years, personal data records are deleted.
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 your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Some data may be retained for legal (including tax) reasons for a period exceeding that which we require for our business purposes.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
Suppliers
Supplier personal data is retained in line with any obligations under the law (e.g. to defend against a legal claim or for HMRC purposes). Once our obligations are fulfilled, personal data is deleted without undue delay in line with our internal processes.
9. LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
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Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
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Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
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Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
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Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
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Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us using the details set out at the start of this privacy notice.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
GLOSSARY
Candidates – refers to applicants (and those subsequently engaged on temporary assignments, directly or indirectly, by Key Recruitment) for any roles advertised by or through Key Recruitment, whether permanent or temporary positions, whether as freelancers, contractors, flexible employees or through third parties including Suppliers; as well as people who have submitted a speculative CV to Key Recruitment.
Clients – this refers to our customers, clients, and others to whom Key Recruitment provides services in the course of its business.
General Data Protection Regulation – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.
Staff – includes current and former employees and interns engaged directly in the business of Key recruitment (or who have accepted an offer to be engaged) as well as certain other workers who are or were engaged in the business of providing services to Key Recruitment (even though they are not classed as employees).
Suppliers – covers supplier companies (including sole traders), vendors, umbrella companies, partnerships and limited company contractors who provide services to Key Recruitment including as sub-contractors. Suppliers should ensure their employees and workers are made aware of the provisions of this Privacy Policy as applicable.
Website Users – any individual who accesses any of the Key Recruitment website.
