1st May 2018
It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
This Policy sets out the obligations of Cameron James Professional Recruitment, a company registered in Leeds, United Kingdom under number 07476210, whose registered office is at West One, 114 Wellington Street, Leeds, LS1 1BA ("Cameron James" or "Us") regarding data protection and the rights of candidates in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation ("GDPR").
What kind of personal data do we collect?
CANDIDATE DATA: 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 your name, age, contact details, education details, employment history, emergency contacts, immigration status, financial information (where we need to carry out financial background checks), and national insurance number (and of course you may choose to share other relevant information with us).
Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship.
Where appropriate and in accordance with local laws and requirements, we may also collect other information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests;
- Marital status
- Contact details
- Referee details
- Nationality/citizenship/place of birth
- Copy of your driving licence and/or passport/identity card, Social security number (or equivalent in your country) and any other tax-related information
- Diversity information such as disability-related information
- Details about your current remuneration, pensions and benefits arrangements
- Information on your interests and needs regarding future employment
- Criminal convictions.
- Extra information that you choose to tell us or information that your referees chooses to tell us about you
The main reason for using your personal details is to help you find employment or other work roles that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service
CLIENT DATA: If you are a Cameron James customer, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as finding Candidates who are the right fit for you or your organisation.
The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We may also hold extra information that someone in your organisation has chosen to tell us. We also hold information relating to your engagement with Cameron James such as past vacancies and instructions.
SUPPLIER DATA: We need a small amount of information from our Suppliers to ensure that things run smoothly. We need contact details of relevant individuals such as names, telephone numbers and email addresses so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).
REFEREES AND EMERGENCY CONTACTS: In order to provide Candidates with suitable employment opportunities safely and securely, we need some basic background information and confirmation of what we already know about our Candidate or prospective member of Staff, Emergency contact details give us somebody to call on in an emergency. To ask for a reference, we'll obviously need the referee's contact details (such as name, email address and telephone number).
How do we collect your personal data?
- CANDIDATE DATA: There are two main ways in which we collect your personal data:
- 1. Personal data that you, the Candidate has given to us
- 2. Personal data that we receive from other sources
Cameron James needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities, and should save you time in not having to trawl through information about jobs and services that are not relevant to you. There are numerous ways you can share your information with us. It all depends on what suits you. These may include;
- Entering your details on the Cameron James website or via an application form, as part of the registration process
- Emailing your CV to a Cameron James consultant or being interviewed by them
- Leaving a hard copy CV at a Cameron James recruitment event, job fair or office
- Applying for jobs through a job board, which then redirects you to the Cameron James website
We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:
- Our Clients may share personal information about you with us
- Your referees may disclose personal information about you
- We may obtain information about you from searching for potential Candidates from third party sources, such as LinkedIn and other job sites
CLIENT DATA: There are two main ways in which we collect your personal data:
- 1. Directly from you
- 2. From third parties (e.g. our Candidates) and other limited sources (e.g. online and offline media, company websites).
We both share the same goal - to make sure that you have the best staff for your organisation. We will receive data directly from you in two ways:
- Where you contact us proactively, usually by phone or email; and/or
- Where we contact you, either by phone or email, or through our consultants' business development activities more generally.
Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:
- Delegate lists at relevant events
- Third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us);
- Other limited sources and third parties (for example from our Candidates to the extent that they provide us with your details to act as a referee for them).
SUPPLIER DATA: We collect your personal data during the course of our work with you.
REFEREES AND EMERGENCY CONTACTS: We collect your contact details only where a candidate or a member of our Staff puts you down as their emergency contact or where a candidate gives them to us in order for you to serve as a referee.
How do we use your personal data?
Having obtained data about you, we then use it in a number of ways.
CANDIDATE DATA: We generally use Candidate data in three ways:
- Recruitment Activities
- Equal Opportunities Monitoring
- Marketing Activities
Here are some more details about each:
Recruitment Activities; Clearly our main area of work is recruitment - connecting the right candidates with the right jobs. We have listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive;
- Sending your information to Clients, in order to apply for jobs or to assess your eligibility for jobs
- Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment
- Providing you with our recruitment services and to manage the recruitment process
- Collecting your data from you and other sources, such as LinkedIn
- Assessing data about you against vacancies which we think may be suitable for you
- Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you
- Carrying out our obligations arising from any contracts entered into between Cameron James and third parties in relation to your recruitment
- Facilitating our payroll and invoicing processes
- Carrying out customer satisfaction surveys
- Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.
- Request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws)
- Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties
We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests.
Equal opportunities monitoring and other sensitive personal data; We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. This could be information about your ethnic background, gender, disability or age. Where appropriate and in accordance with local laws and requirements, we may disclose this (suitably anonymised where relevant) data to Clients where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes.
Marketing Activities; We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. To:
- Market our full range of recruitment services (permanent, temporary, contract) to you
- Enable us to develop and market other products and services
- Send you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you
We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular the delivery of direct marketing to you through digital channels) and, depending on the situation, we'll ask for this via an opt-in or soft-opt-in (which we explain further below). Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time.
Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services. Under 'soft opt-in' consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the chances of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent.
CLIENT DATA: We use Client information for:
- Recruitment Activities
- Marketing Activities
- Help us to establish, exercise or defend legal claims
The main reason for using information about Clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. This may involveidentifying Candidates who we think will be the right fit for you or your organisation and the more information we have, the more bespoke we can make our service.
Recruitment Activities; Our main area of work is recruitment, through providing you with candidates. We have listed below the different ways in which we use your data in order to facilitate this;
- Keeping records of our conversations and meetings, so that we can provide targeted services to you
- Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment activities
- Processing your data for the purpose of targeting appropriate marketing campaigns.
- Undertaking customer satisfaction surveys
If you are not happy about this, in certain circumstances you have the right to object.
Marketing Activities; We will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address (subject to any applicable local laws and requirements). If you are not happy about this, you have the right to opt out of receiving marketing materials from us.
Establish, exercise or defend legal claims; In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
SUPPLIER DATA: The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.
REFEREES AND EMERGENCY CONTACTS: We use referees' personal data to help our candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective employers. We may also use referees' personal data to contact them in relation to recruitment activities that may be of interest to them. We use the personal details of a candidates or staff member's emergency contacts in the case of an accident or emergency affecting that Candidates or member of staff.
WEBSITE USERS: We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present jobs to you that we think you'll be interested in. If you are also a Candidate or Client of Cameron James, we may use data from your use of our websites to enhance other aspects of our communications with, or service to, you.
Who do we share your personal data with?
CANDIDATE DATA: We may share your personal data with various parties for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing the job you want, such as;
- Potential employers /organisations to increase your chances of finding employment
- Third party partners, job boards and job aggregators where we consider this will improve the chances of finding you the right job
- Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation)
- Third party service providers who perform functions on our behalf (including business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and service consultants carrying out testing and development work on our business technology systems)
- Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies
- Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place
CLIENT DATA: We will share your dataprimarily to ensure that we provide you with a suitable pool of Candidates.
How do we safeguard your personal data?
We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data. We have taken the following measures;
- All emails containing personal data are encrypted
- We use secure networks which are backed up daily with back-ups stored offsite. Our back-ups are encrypted.
- We securely store our personal data and all electronic copies of personal data are secured using passwords.
- All hardcopies of personal data, along with any electronic copies stored on physical, removable media are stored securely in a locked box, drawer, cabinet, or similar
How long do we keep your personal data for?
We shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed. We will contact you every 36 months to review the personal data we hold is correct and you still wish for us to hold this. When personal data is no longer required or you don't want us to keep it, all reasonable steps will be taken to erase or otherwise dispose of it without delay. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
How can you access, amend or take back the personal data that you have given to us?
One of the GDPR's main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. Even if we already hold your personal data, you still have various rights in relation to it, described below;
- Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
- Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for profiling your suitability for certain roles), or consent to market to you, you may withdraw your consent at any time.
- Data Subject Access Requests (DSAR): Just so it's clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or Delete such information. We will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. At this point we may comply with your request or, additionally do one of the following:
- We may ask you to verify your identity, or ask for more information about your request
- Where we are legally permitted to do so, we may decline your request, but we will explain why if we do so (for example we are processing your data for the establishment, exercise or defence of a legal claim).
- Right to erasure: In certain situations (for example, where we have processed your data unlawfully, the data is no longer necessary or you have withdrawn your consent), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data is collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
- Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.If your interests or requirements change, you can unsubscribe from part or all of our marketing content (for example job role emails) by clicking the unsubscribe link in the email.
- Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority.
Our legal basis for processing your data
Article 6(1)(f) of the GDPR says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."
We don't think that any of the following activities prejudice individuals in any way - in fact, they help us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis.
We think it's reasonable to expect that if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our bank of vacancies. Once it's looking like you may get the job, your prospective employer may also want to double check any information you've given us (such as the results from psychometric evaluations or skills tests) or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws. We need to do these things so that we can function as a profit-making business, and to help you and other Candidates get the jobs you deserve.
We want to provide you with tailored job recommendations and relevant articles to read to help you on your job hunt. We therefore think it's reasonable for us to process your data to make sure that we send you the most appropriate content.
We have to make sure our business runs smoothly, so that we can carry on providing services to Candidates like you. We therefore also need to use your data for our internal administrative activities, like payroll and invoicing where relevant.
We have our own obligations under the law, which it is a legitimate interest of ours to insist on meeting! If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.
To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable - we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.
We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.
REFEREES AND EMERGENCY CONTACTS:
If you have been put down by a Candidate or a prospective member of Staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves. If a Candidate or Staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.
In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
Article 4(11) of the GDPR states that (opt-in) consent is "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her." In plain language, this means that:
- You have to know what you are consenting to - so we'll make sure we give you enough information
- You have to give us your consent freely, without us putting you under any type of pressure
- You need to take positive and affirmative action in giving us your consent - we're likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
- You should have control over which processing activities you consent to and which you don't. We provide these finer controls within our privacy preference centre
- We will keep records of the consents that you have given in this way.
We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the recruitment services we provide as long as you do not actively opt-out from these communications.
As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time by contacting us.
ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS
Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity". This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
How you can get in touch with us
You can do this by contacting firstname.lastname@example.org or writing to us at our Head Office address;West One, 114 Wellington Street, Leeds, LS1 1BA
If you have any queries regarding;
- Access, amend or take back the personal data that you have given to us
- If you suspect any misuse or loss of or unauthorised access to your personal information
- Withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data)