Tanton HR Recruitment

PRIVACY POLICY – TANTON HR RECRUITMENT LIMITED

This privacy policy sets out how Tanton HR Recruitment Limited (“THR”) uses and protects any personal information that you give to us. Whether you are in the process of looking for a new position as a candidate, continuing our relationship with you after a suitable position has been found, providing you with a service in relation to industry or market knowledge, providing a service to you as a client, or when you use our website.

We respect your privacy and are committed to protecting your personal data. We will be open and transparent about how we collect and use data ensuring that your privacy is protected. We do this in accordance with Data Protection legislation currently in force. Should we ask you to provide certain information throughout your dealings with us, you can be assured that it will only be done in a lawful, fair and transparent way and in accordance with this privacy notice.

1) IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how THR collects and processes your personal data through your contact with THR, including any data you may provide through this website, by phone, by post or on job boards or other online platforms when you sign up to our services or make an enquiry with us.

Our website www.tantonhr.co.ukis not intended for children and we do not knowingly collect data relating to children.

Controller

Tanton HR Recruitment Limited is the controller and responsible for your personal data (collectively referred to as THR, “we”, “us” or “our” in this privacy notice).

We have appointed a Data Compliance Manager 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 the Data Compliance Manager using the details set out below.

Contact details

Full name of legal entity: Tanton HR Recruitment Limited

Name of Data Compliance Manager: Paul Tanton

Email address: paul@tantonhr.co.uk

Postal address: Tanton HR Recruitment Limited

Woodgates

Manor Crescent

Haslemere

Surrey

GU27 1PB

Telephone number: 07939 108479

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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Third-party links

Our 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

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

· Identity Data includes first name, last name and title (including position held).

· Contact Data includes home address, work address, email addresses and telephone numbers.

· Work History Data (Candidates)includes full curriculum vitae, employment history, qualifications, references, salary information (both existing and proposed) and any other details you have provided to us necessary for us to support your employment applications.

· Financial Data includes bank account and payment card details.

· Transaction Data includes details about payments to and from you, and other details of services we have provided to you.

· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

· Profile Data includes your username and password, services requested by you, your interests, preferences, organisation and management structure information, direct team structures, feedback and survey responses.

· Usage Data includes [information about how you use our website and services.

· Marketing and Communications Dataincludes your preferences in receiving marketing from us and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3) HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Work History and Financial Data by contacting us on our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

· apply for a job on our website;

· create an account on our website;

· subscribe to our service or publications;

· request job opportunities/vacancies to be sent to you;

· approach us to market and provide prospective candidates to fill a job role; or

· give us some feedback.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

· Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the EU.

· Identity, Contact and Work History Data from platforms such as job advertising boards, LinkedIn or social media platforms based inside the EU.

· Identity and Contact Data from third-party introductions from clients, candidates (current and past) and business contacts.

· Identity and Contact Data from general business marketing activities in line with our legitimate business interests.

4) HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Candidates We may use your personal information as follows:

· Where we need to perform the contract we are about to enter into or have entered into with you.

· To assist you in finding a suitable employment opportunity. The information is used to assess your skills, qualifications and suitability for positions that we manage on behalf of our customers.

· In conjunction with our legitimate business interests to conduct activities such as marketing and research analysis and your interests and fundamental rights do not override those interests.

· The information may also be used to establish, exercise or defend a legitimate legal claim.

· Marketing activities to alert you to new positions, make you aware of new services we offer, for market research, for invites to networking or industry sector events. These activities are processed in line with The Privacy and Electronic Communications (EC Directive) Regulations 2003.

· Where we need to comply with a legal or regulatory obligation.

Clients We may use your information as follows:

· Where we need to perform the contract we are about to enter into or have entered into with you.

· To supply suitable candidates to you in relation to recruitment projects. The more information we hold on you the better service we can provide.

· In conjunction with our legitimate business interests to conduct activities such as marketing and research analysis and your interests and fundamental rights do not override those interests.

· Where we need to comply with a legal or regulatory obligation.

· The information may also be used to establish, exercise or defend a legitimate legal claim.

· Marketing activities to alert you to new positions if you, as our customer, are also considering a new role, make you aware of new services we offer, for market research, for invites to networking or industry sector events. These activities are processed in line with The Privacy and Electronic Communications (EC Directive) Regulations 2003.

Third Parties and Suppliers We may use your information as follows:

· To obtain employment references on behalf of candidates and clients.

· To verify qualification details for candidates on behalf of clients.

· To legitimately communicate with you as our supplier.

· In conjunction with our legitimate business interests to conduct activities such as marketing and research analysis.

· The information may also be used to establish, exercise or defend a legitimate legal claim or to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message.

You have the right to withdraw consent to marketing at any time by contacting us at paul@tantonhr.co.uk

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that 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 contact us 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 below in A) to E):-

A) Purpose/Activity

To register you as a new Candidate or Client

Type of data

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you

___________________________________________________________________

B) Purpose/Activity

To manage our relationship with you which will include:

(a) Notifying you about prospective job opportunities or available candidates.

(b) Notifying you about changes to our terms or privacy policy

Type of data

(a) Identity

(b) Contact

(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated, to notify you about job opportunities and to study how customers use our services)

__________________________________________________________________

C) Purpose/Activity

To process and manage the contract with you:

(a) Manage contract fees

(b) Collect and recover money owed to us

Type of data

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

___________________________________________________________________

D) Purpose/Activity

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

___________________________________________________________________

E) Purpose/Activity

To make suggestions and recommendations to you about employment opportunities or available candidates that may be of interest to you

Type of data

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Technical

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to develop our products/services and grow our business)

___________________________________________________________________

Marketing Communications from us

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Work History, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have made contact with us, requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of THR for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us on paul@tantonhr.co.uk at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service provided or where we have had some other lawful basis for processing your personal data but you will no longer receive any marketing messages from us.

Cookies

We do not use Cookies on our website. Our website is solely to gain client and candidate information for the purposes of offering a recruitment service.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at paul@tantonhr.co.uk.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5) 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 section 4 above.

· External Third Parties as set out in the Glossary.

· 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.

6) INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (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. 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.

8) DATA RETENTION

How long will you use my personal data for?

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.

Unless we hear from you to the contrary, we will delete your personal information after a period of five years, should we have no contact with you in the interim. This period is subject to any legal and regulatory requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for [six] years after they cease being clients or candidates for tax purposes.

In some circumstances you can ask us to delete your data: see Data Subject Rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9) YOUR LEGAL RIGHTS

You have the right to:

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.

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.

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.

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.

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.

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.

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.

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.

If you would like to exercise any of these rights please email Paul Tanton, Director and Data Compliance Manager on paul@tantonhr.co.uk

10) GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at paul@tantonhr.co.uk

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

· Clients/Candidates with whom we have contracted to provide our services.

· 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 who require reporting of processing activities in certain circumstances.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 28th January 2021.

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.

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