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nick_dev | 3rd November 2016

GDPR – Our Privacy Statement

Company Name:	Profiles Personnel (Farnham) Ltd
Company Contact details:	Nuala Soutter MD Profiles Personnel 74 Castle Street, Farnham, Surrey GU9 7LS
	GDPR Privacy Notice
Topic:	Data protection
Date:	25/5/2018
Version:	1

This Privacy Notice tells you what to expect in relation to personal information about you which is collected, handled and processed by Profiles Personnel (Farnham) Limited.  Profiles Personnel (Farnham) Ltd is the Data Controller. We acknowledge and agree that any personal data of yours that we handle will be processed in accordance with all applicable data protection laws in force from time to time. With effect  from 25th May 2018 the General Data Protection Regulations (“GDPR”) will come into force which will change the law.

Profiles Personnel is a recruitment business which provides work-finding services to its clients and work-seekers. We must process personal data (including sensitive personal data) so that it can provide these services – in doing so, Profiles Personnel acts as a data controller.

You may give your personal details to Profiles Personnel directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. Profiles Personnel must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws.

• Collection and use of your personal data
• Purpose of processing and legal basis

Profiles Personnel will collect your personal data (which may include sensitive personal 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, arranging payments to you 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:

• Where we have a legitimate interest
• Legitimate interest

This is where Profiles Personnel 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 Profiles Personnel has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

• Managing our database and keeping work-seeker records up to date;
• Providing work-finding services to you and our clients;
• Contacting you to seek your consent where we need it;
• Statutory/contractual requirement

Profiles Personnel 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, immigration and tax legislation, and in some circumstances safeguarding requirements.)  Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. 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 eg. Right to work documentation, Payroll and Tax information.

• Recipient/s of data

Profiles Personnel will process your personal data and/or sensitive personal data with the following recipients:

• Clients (whom we may introduce or supply you to)
• Former employers whom we may seek references from
• Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to along with pension scheme providers
• Other recruitment agencies in the supply chain
• Your information

The information about you we may collect, hold and process is set out below

Personal data:

• Name, address, mobile no., email
• National insurance no.
• Nationality (through right to work check)
• CV, Passport, Visa, Photo
• References
• Job Preferences including role, geographical areas and salary
• Bank Details
• Financial information (including but not limited to payroll details and terms. HMRC data, pension scheme details, court orders and statutory payments
• A log of our communications with you by email and telephone

Sensitive personal data:

• Outcome of criminal record checks and in certain cases medical information

Source of the personal data:

Profiles Personnel sourced your personal data:

• From  jobs boards, LinkedIn, Social Media, Career Fairs, our Website
• Referral Schemes
• Software providers who we use to support our services including Logic Melon

This information came from a publicly accessible source.

• Sharing your information

Profiles Personnel will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

• Retaining your data

Profiles Personnel 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.

We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently 3 to 6 years.

We only want to hold your information if you are or will be soon looking for work.  We therefore ask you to notify us as soon as you are no longer in the market for new employment to enable us to delete all information safely and securely.

• Your rights

Please be aware that you have the following data protection rights:

• The right to be informed about the personal data Profiles Personnel processes on you;
• The right of access to the personal data Profiles Personnel 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.

Where you have consented to Profiles Personnel processing your personal data you have the right to withdraw that consent at any time by contacting nuala@profiles-personnel.com Data Protection Officer. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where Profiles Personnel will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.

If you believe that any of your data that Profiles Personnel processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

• Cookies

We may obtain data about you from cookies.  These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, please refer our cookie policy on our website

• Links to external websites

Profiles Personnel’s website may contain links to other external websites. Please be aware that Profiles Personnel is not responsible for the privacy practices of such other sites.  When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by Profiles Personnel’s website.  

• Sale of business

If Profiles Personnel’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

• Marketing

We like to communicate with our candidates and all mailers and newsletters include an ‘unsubscribe’ function, which is quick and easy to use from both a desktop and mobile device.

• Data Security

Profiles Personnel takes every precaution to protect our users’ information. Only employees who need the information to perform a specific job are granted access to your information.

Profiles Personnel uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason Profiles Personnel cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet.

If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered.

If you have any questions about the security at our website, you can email

nuala@profiles-personnel.com

• Changes to this privacy statement

We will update this privacy statement from time to time.  We will post any changes on the statement with revision dates.  If we make any material changes, we will notify you.

• Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact

Nuala Soutter, Profiles Personnel, 74 Castle Street, Farnham, Surrey GU9 7LS nuala@profiles-personnel.com

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.