Client’s Privacy notice
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We collect information about you to carry out our core business and ancillary activities.
This privacy notice provides you with details of how St Pancras Recruitment Ltd (“we”, “our”, “us”, or “the Company”) collect and Process your Personal Data, whether you’re a client, a candidate, a supplier or another third party.
“Personal Data” is any information identifying a living, identifiable individual, excluding any anonymous data but including any sensitive Personal Data. Such data can be factual such as a name, email address, date of birth or national insurance number; or an opinion or reference about a person’s actions or behaviour.
“Processing” or “Process” means any activity involving the use of Personal Data whether that is obtaining, holding, recording or carrying out any operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. It includes the transmission or transferring Personal Data to third parties. St Pancras Recruitment Ltd is the data controller and we are responsible for your Personal Data, including determining when, why and how to Process Personal Data. Our email address is [email protected] Our postal address is St Pancras Chambers, Euston Road, NW1 2AR London. If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you. It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected]
This policy has been written in accordance with the principles and safeguards set out in the General Data Protection Regulation (EU) 2016/679) (“GDPR”) We adhere to the principles relating to the Processing of Personal Data set out in GDPR which require Personal Data to be:
(a) Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency). (b) Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
(c) Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).
(d) Accurate and where necessary kept up to date (Accuracy).
(e) Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).
(f) Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).
(g) Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
(h) Made available to individuals such us to allow them to exercise certain rights in relation to their Personal Data (Data Subject’s Rights and Requests).
HOW WE USE YOUR PERSONAL DATA
We will only use your Personal Data when legally permitted. The most common uses of your Personal Data are: Where we need to perform the contract between us either (i) in accordance with our terms and conditions of business if you are a client; ii) in accordance with our terms of representation if you are a candidate or (iii) in accordance with the relevant terms of supply between us as businesses. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation. Generally, we do not rely on consent as a legal ground for Processing your Personal Data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at [email protected] Purposes for Processing your Personal Data Set out below is a description of the ways we intend to use your Personal Data and the legal grounds on which we will Process such data. We have also explained what our legitimate interests are where relevant. We may Process your Personal Data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at [email protected] if you need details about the specific legal ground we are relying on to Process your Personal Data where more than one ground has been set out in the table below.
To register you as a new client (a) Identity (b) Contact (c) Details concerning your family Lawful basis for processing: To find a suitable candidate for your family in accordance with our legal terms and conditions of business.
To register you as a new candidate (a) Identity (b) Contact (c) Job experience (d) Skills and qualifications Lawful basis for processing: To comply with your legal terms and conditions of representation and use all reasonable endeavours to find you suitable employment / engagement.
To Process your invoice: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (1) Identity (2) Contact (3) Financial (4) Transaction (5) Marketing and Communications Lawful basis for processing: (a) Performance of a contract with you (b) Necessary for our legitimate interests to recover debts owed to us
To manage our relationship with you as a supplier (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications Lawful basis for processing: (a) Performance of a contract with you (b) Necessary for our legitimate interests to manage and run our business
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical Lawful basis for processing: (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security and to prevent fraud. (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, services, marketing, client relationships and experiences (a) Technical (b) Usage Lawful basis for processing: Necessary for our legitimate interests to define types of clients for our services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy.
To make suggestions and recommendations to you about services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile Lawful basis for processing: Necessary for our legitimate interests to develop our services and grow our business.
Information we obtain from other sources.
We are working closely with third parties including Nannytax and Parental Choice Limited. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Marketing communications You will receive marketing communications from us if you have: (i) requested information from us or registered with us as a candidate or client; or (ii) if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and (iii) in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by emailing us at [email protected] at any time. Where you opt out of receiving our marketing communications, this will not apply to Personal Data provided to us as a result of us providing you with a service or other transaction.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your Personal Data with the parties set out below for the purposes set out in the table in paragraph 2 above: Clients who are looking for suitable candidates to fulfil a role that they are offering. Service providers who provide IT and system administration services. Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of Processing activities in certain circumstances. Third parties to whom we sell, transfer, or merge parts of our business or our assets. We require all third parties to whom we transfer your data to respect the security of your Personal Data and to treat it in accordance with the law. We only allow such third parties to Process your Personal Data for specified purposes and in accordance with our instructions.
We do not transfer your Personal Data outside the European Economic Area.
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. 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 such data. 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 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. 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. By law we must keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes. In some circumstances you can ask us to delete your data and it is our responsibility to make sure that any Personal Data we retain is accurate. So, if you would like us to erase your data (to the extent that we are able) or there are any changes to your data which means what we currently hold is inaccurate, please do let us know.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. These include the right to: * Request access to your Personal Data. * Request correction of your Personal Data. * Request erasure of your Personal Data. * Object to Processing of your Personal Data. * Request restriction of Processing your Personal Data. * Request transfer of your Personal Data. * Right to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email us at [email protected] 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. 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. 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 several requests. In this case, we will notify you and keep you updated.
Candidate’s privacy notice
St Pancras Recruitment is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for jobs we are recruiting for on behalf of our clients. It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
GDPR is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
WHO WE ARE AND WHAT WE DO
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We collect the personal data on prospective and placed candidates for permanent or temporary roles to allow us to undertake our business.
DATA PROTECTION PRINCIPLES
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
In connection with your application for a job or jobs with us, we will collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae and covering letter.
- The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, and qualifications.
- Any information you provide to us during an interview.
- The information you have provided to us in your background documents, including but not limited to, passport, driving licence, first aid certificate, right to work visa etc.
- Information provided to us about you as a result of collecting and reviewing references.
We may also collect, store and use the following “special categories” of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences.
We will only process the above personal information in order to assess your working capacity and to protect your interests. We will not disclose such information to any third party unless you expressly confirm we are able to. All such information shall be kept strictly confidential.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about candidates from the following sources:
- You, the candidate.
- Disclosure and Barring Service in respect of criminal convictions.
- Your named referees, from whom we collect the following categories of data: details of previous employment, conduct, health and sickness records. You will need to tell us that you have their authority for us to contact them before we collect any such information from them.
HOW WE WILL USE INFORMATION ABOUT YOU
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the any positions we currently have available and may be of interest to you.
- Carry out background and reference checks, where applicable.
- Communicate with you about the recruitment process.
- Communicate with potential employers looking to hire candidates such as you
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to put you forward for a role, which we will discuss fully with you before submitting your details to a potential employer looking to appoint someone to a particular role.
If you fail to provide personal information.
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a DBS check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
We will use your particularly sensitive personal information in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during the interview as well as during employment.
- We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We envisage that we will process information about criminal convictions. If an employer wishes to offer you a role, we will collect information about your criminal convictions (conditional on checks and any other conditions, such as references, being satisfactory). We are required to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:
- The role of a nanny is one which is listed on the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (SI 1975/1023) and is also specified in the Police Act 1997 (Criminal Records) Regulations (SI 2002/233)] so is eligible for an enhanced check from the Disclosure and Barring Service.
- The role of a nanny requires a high degree of trust and integrity since it involves dealing with children and so we would like to ask you to seek a basic disclosure of your criminal records history.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties? We will share your information to potential employers for the purpose of securing you a job as set out in our terms of representation. We will only share your personal information with the following third parties for the purposes of processing your application: Disclosure and Barring Service, regulatory authorities and any other body as required by law. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for? We will retain your personal information for a period of 24 months after we have processed your information for the purpose of finding you a role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations. If we wish to retain your personal information on file beyond 24 months, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a further fixed period on that basis. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION Your rights in connection with personal information Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Marine Lienard in writing.
RIGHT TO WITHDRAW CONSENT
When you apply for any vacancy through St Pancras Recruitment you will have provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact Marine Lienard. Once we have received notification that you have withdrawn your consent, we will no longer process your date and will refrain from submitting your data to any potential employers and, subject to our retention policy, we will dispose of your personal data securely.