Privacy Policy.

In line with the new General Data Protection Regulation (GDPR) all organisations which process personal data must ensure that they comply with its regulations and principles.

We must ensure that:

• We are lawful, fair and transparent in the way that data is processed
• Personal data is used for a specific purpose
• We only record data that is required
• We maintain our duty to keep data accurate
• Data is only kept for as long as is required
• All data is stored securely

This Privacy Notice will detail how we comply with the above principles as well as your rights as the data owner.

1) Who are we?

Intro Recruitment Limited is a recruitment consultancy based in the North West of England. We specialise in recruitment into the office and engineering sectors under the name of “Intro Recruitment.” Under GDPR we are defined as a “Data Controller”.

2) What data do we collect?

Personal data refers to any data that can be used to identify a natural person and we only process information that we need in order assist with your job search. Depending on your relationship with us, we may collect some or all of the information detailed below (please note this list is not exhaustive):

For Candidates:

• Name
• Address
• Date of birth
• Contact numbers
• Email information
• Social Media information
• Employment history including salary and benefits
• Education & Qualifications
• Referee information
• Any other information given to us by your referee
• Visa information
• If you have any criminal convictions
• If you have been involved in any disciplinary action
• If you have any medical conditions or disabilities
• Copy of passport or other proof of identification and eligibility to work in the UK e.g. driving licence, birth certificate
• P45 information
• Gender
• Bank details
• National insurance details
• Emergency contact details
• Next of kin details

For Clients:

For clients we process minimal information on you and/or employees of your organisation so that we are able to assist with any recruitment needs you may have. Types of information processed are: company address, contact number, work emails, job titles and website. We log any interaction between clients and Intro Recruitment in relation to candidates in the form of CV submits, interviews, placements and with clients & Intro Recruitment in the form of emails and telephone calls.

For Suppliers:

In order to make sure that our relationship runs without any hitches we hold a small amount of information on our suppliers. This information will be held about our contacts within your business and usually relates to name, address, contact number and emails. We will also hold your bank details so that we can pay you.

Other Information we may hold:

As mentioned above we are required to obtain referee information and act upon this information to enable you to secure your role. This information is usually name, company, job title, contact number and email.

We also hold emergency contact and next of kin information for our members of staff. If your information is provided to us for this purpose it will only be used for the nature it was given and the information provided is usually name, address, relationship, contact number and email.

3) How do we collect your data?

The majority of the data we hold is freely given by the data owner and can be provided in a number of different ways:

For Candidates:

• When you apply into one of our job adverts
• When we source your data from a 3^rd party (e.g. Job boards, LinkedIn)
• When you directly email in your CV

For Clients:

• When we have been involved in previous recruitment activity within your business
• When we have received calls from yourself in relation to recruitment within your business
• When our consultants have contacted you by means of business development activity
• When we have attended the same networking events
• When you have been identified as a reference provider

For Suppliers:

• When a purchase has been made
• From information provided on your invoice

Others:

• Through the completion of relevant forms by the employee when starting with Intro Recruitment

4) What is our Legal Basis for Processing your data?

When you provide your data, we will do our utmost to protect your information and support you in your job search. GDPR states that we are required to let you know under which legal basis your data is processed.

We are using Legitimate Interest as our legal basis for processing the following data:

Legitimate Interest – Article 6(1)(f) says:

“processing is necessary for the purpose of the legitimate interest pursued by the controller or by the third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data”

For Candidates:

When you provide us with your CV, apply to one of our adverts or upload your CV onto a job board, it is reasonable to expect that you will be contacted by us about your job search and any potential suitable vacancies.

You may not be successful in your initial application, however, by using the information you have provided, we can let you know about any future vacancies that may be suitable for you.

We will always have an initial telephone conversation with you, so we can fully understand your career experience to date and what you are looking for, so we can provide you with a tailored service. We also inform you what you can expect from us and how your data will be used. We will arrange face to face meetings but if this is not possible, these may be completed by Skype or Facetime.

For Clients:

We want to ensure that we provide you with the best possible service and so we hold data on your business and the contacts within your business that we may need to have conversations with. We log details of conversations, emails sent and received, meetings, vacancies and placements.

For Suppliers:

In order to ensure prompt payment for services you have provided, we need to hold certain information on you and your business so that payments can be made.

For Others:

We may hold your information if it has been provided to us as a reference for a new employee or a candidate for whom we have secured a placement.

The data noted above is necessary for our legitimate interest as a recruitment consultancy to provide a comprehensive recruitment service to our candidates, clients and new employees.

If you are a member of staff of Intro Recruitment or are working for us on a temporary contract with one of our clients, there is certain data that we require in order to process payroll – for this information we are using Legal Obligation as the legal basis for processing.

Legal Obligation – Article (6)(1) (c) says:

“processing is necessary for compliance with a legal obligation to which the controller is subject.”

5) Why do we collect your data?

Our core business activity is to provide opportunities for our candidates and to support our clients to enable us to provide the best candidate to suit the business needs. In order to be able to do this we need to understand:

For Candidates:

• Who you are and what type of roles you are looking for
• Have means to contact you via phone and/or email
• Where you live in order to be able to contact you about opportunities
• Your work history and qualifications

For Clients:

• Your position within the business to ascertain who is the correct person to speak with
• Have means to contact you via phone and/or email

6) How do we use your data?

Your data is used for Recruitment and Marketing activity.

For Candidates:

In order to be able to place the right candidate in the right job, your data may be used in one or more of the following ways:

• Storing and updating your information on our CRM system so that we can contact you about recruitment opportunities
• Using your data to identify your suitability for recruitment opportunities
• Speaking to clients about you in relation to recruitment within their business
• With your agreement, sending your CV to clients in relation to a specific vacancy
• Emailing and speaking to clients about you and your experience to generate further recruitment opportunities
• Emailing you information relating to specific recruitment or marketing information which we think maybe of interest to you
• Speaking to previous employers to provide a reference
• If placed in a temporary position, we will use your financial details for payroll purposes

For Clients:

In order to find you the best candidate, your data may be used in one or more of the following ways:

• Storing and updating your information on our CRM system so that we can contact you in relation to recruitment activities
• Calls in relation to potential candidates
• Calls in relation to recruitment activity within your business
• Emails in relation to potential candidates
• Marketing information about events we are holding that maybe of interest to you
• Marketing information in relation to the services we can provide
• Keeping records of conversations, emails and meetings to reference if needed in relation to any dispute

For some of the above activities your consent is required. For more information on how we obtain and manage your consent please refer to section 11 in this document.

7) Who do we share your data with?

In some circumstances we may need to share your details with a third party. This will include but is not limited to sharing data with:

For Candidates:

• Potential new employers
• Past employers named as reference providers
• Umbrella companies used to provide payroll services
• Service providers who provide IT and system office services, marketing platforms and website hosting 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
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

For Clients:

• Information may be shared with potential candidates if you have requested this

8) How do we safeguard your data?

Your data is of the utmost importance to us and as such we ensure relevant security is in place in order to keep your data safe and protected from any potential threats.

For more information please refer to our Data Protection Policy which is available upon request. Our contact information can be found at the end of this document.

If for any reason you believe we have not taken appropriate care of your data and it has been misused, please contact us immediately. Our contact information can be found at the end of this document.

9) How long do we keep your data for?

Please refer to our Retention & Erasure Policy which is available upon request. Our contact information can be found at the end of this document.

10) Your Rights.

GDPR provides the following rights:

• The Right to be Informed.
  You have the right to be informed about the collection and use of your personal data and you must be provided with certain information including the purpose for processing your personal data, our retention periods for the data and who it will be shared with.All this information is provided by means of this Privacy Notice.

• The Right of Access.
  You have the right to access your personal data and any supplementary information. This is known as a Data Subject Access Request (DSAR) and when received by us, we are legally required to provide this information within one month.This information will be provided free of charge unless we feel the request is unfounded or excessive, particularly if it is repetitive. A fee may also be charged if further copies of the same information are requested.

• The Right to Rectification.
  You have the right to have any inaccurate personal data rectified or completed if incomplete. You can request this to be done verbally or in writing and we have one calendar month to respond.There is no fee attached to this request, however, if we feel the request is unfounded or excessive, particularly if it is repetitive, we can charge a fee or refuse the request. If either of these apply we will provide you with our reasons for such action in writing.

• The Right to Erasure (this is also known as the right to be forgotten)
  You have the right to have your personal data erased if:
  • The data is no longer necessary for the reason it was originally collected or processed
  • Your data has been processed under legitimate interest and you object to the processing of your data and we cannot provide an overriding legitimate interest to continue processing.
  • The data has been processed unlawfully (in breach of GDPR)
  • It has to be erased to comply with a legal obligation

  If we have to process your data for one of the following reasons, the right to erasure does not apply:

  • to exercise the right of freedom of expression and information
  • to comply with a legal obligation
  • for the performance of a task carried out in the public interest
  • for archiving purposes in the public interest, scientific research, historic research or statistical purposes
  • in the defence of a claim

• The Right to Restrict Processing
  . You have the right to restrict the processing of your data in certain circumstances. When processing is restricted we are allowed to store enough information to ensure future restriction is respected. We will stop processing data if:
  • you do not agree with the accuracy of your personal data
  • the data has been unlawfully processed
  • to establish or defend a legal claim
  • you object to our legal ground for processing your data

  We can only continue to process your data when the above has been resolved and we will inform you before any restriction is lifted. If your data is restricted it can only be stored if:

  • you give your consent to processing
  • it is for the defence of a legal claim
  • it is for the protection of another person
  • it is for reasons of important public interest

• The Right to Data Portability.You have the right to transfer your details across different services. This right only applies in certain circumstances and:
  • to data that has been provided to a controller by an individual
  • where processing is based on consent or for the performance of a contract
  • when processing is carried out by automated means

  When we receive a portability request we must respond within one month and no fee is applicable. We must provide the information in a structured, commonly used and machine readable format.

• The Right to Object
  You can object to the processing of your data when it is processed under one of the following:
  • our legitimate interest
  • performance of a task in the public interest/exercise of official authority
  • direct marketing
  • processing for scientific/historical research or statistical purposes

  We must stop processing your data unless:

  • we can demonstrate compelling legitimate grounds for processing which override your interest
  • it is being processed for the establishment, exercise or defence of a legal claim

  If your objection relates to direct marketing we must stop this immediately

If your data has been shared with a third party and you request one of your “rights” listed above, we will notify them and act upon the requirements of your request unless this is not possible or involves disproportionate effort.

If you feel we have not handled your request efficiently or are unhappy with the services we have provided in relation to the processing of your data, then you can raise your concerns with the Information Commissioners Office (ICO) https://ico.org.uk/global/contact-us/

11) Consent

As a business, and to comply with Article 6 of GDPR, we have agreed that the legal basis for processing your data will be (depending upon your relationship with us) either “Legitimate Interest” or “Legal Obligation”. As well as complying with the GDPR in relation to direct marketing we have to comply to The Privacy and Electronic Communications Regulations (PECR).

In certain circumstances we are required to have your consent to perform certain activities. This consent can be given in the form of an opt-in or soft opt-in option. We have to ensure your consent is freely given, you understand what you are consenting to, and are able to opt-out and back in at any time.

We are permitted to market information to you in relation to the recruitment services we offer until you advise us otherwise by way of opting out.

You can opt in or out verbally during our initial registration call/meeting, using the tick box on our Registration Form or in writing to Intro Recruitment at the address below. If you are opted in and wish to opt out you can also click on the link provided in one of our marketing emails.

12) Contact Details

If you need to contact us for any reason our details are:

Address
Intro Recruitment
15-21 Library Street
Wigan
WN1 1NN

Contact Number
01942 246223

General Email Address
info@introrecruitmentco.uk