AGILE RECRUITMENT PRIVACY NOTICE
Agile Recruitment Ltd (”We”) are committed to protecting and respecting your privacy.
Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group)
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection legislation in force from time to time the data controller is Agile Recruitment of Lowry House, 17 Marble Street, Manchester M2 3AW. Our nominated representative is Jonathon Webley.
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 of the following types of people to allow us to undertake our business;
- Prospective and placed candidates for permanent or temporary roles;
- Prospective and live client contacts;
- Supplier contacts to support our services;
- Employees, consultants, temporary workers.
We collect information about you to carry out our core business and ancillary activities.
Information you give to us or we collect about you.
This is information about you that you give us by filling in forms on our site www.agilerecruit.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.
The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
Information we collect about you when you visit our website.
With regard to each of your visits to our site we will automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version.
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
Information we obtain from other sources.
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are working closely with third parties including companies within the Agile Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, background checking and credit reference agencies, professional advisors, We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
- To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
- To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
- The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.]
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).
We will only process special categories of personal data and personal data relating to criminal convictions and offences as outlined in Article 9 and Article 10 of the GDPR if you have given your consent for us to do so.
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts. Agile Recruitment has a legitimate commercial interest to collect and process personal data relating to Candidates as well as the collection of personal data relating to Hiring Managers of organisations we provide recruitment services to; or Hiring Managers of organisations we would engage with to offer our services (these can be defined as live & prospective Clients). Organisations that use our services to fill their vacancies would be considered as third parties, though Agile Recruitment has a legitimate interest in sharing Candidate personal data with these organisations as part of its recruitment services
In order to provide permanent and contract recruitment services, it is necessary for Agile Recruitment to process certain types of personal data. The personal data we collect is only used only for the purpose of providing recruitment services. In particular, we use your data to deliver recruitment services by:
- Identifying & selecting Candidates whose skills and/or experience are appropriate for the vacancies and contract assignments detailed to us by our Clients;
- Notifying Candidates of potentially suitable and appropriate permanent jobs or contract assignments;
- Notifying Hiring Managers of the availability of suitably skilled workers (Candidates).
As a Candidate your data may also be used for:
- Assisting our Clients to identify and select suitable Candidates for interview on permanent vacancies and contract assignments;
- Processing of pre-employment screenings;
If we provide recruitment services to you, as Candidate or Client, we will also need to ensure compliance with relevant laws and regulations in the jurisdictions that we operate, such as:
- social legislation
Because we provide recruitment services to our Clients (who may be the organisations subject to the above laws and regulation), we may need to process Candidate personal data to meet contractual obligations with our Clients, but we will always obtain further consent from a Candidate where required by law.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses we will make of your data:
- Use of our website;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process.
Disclosure of your information inside and outside of the EEA
We will share your personal information with:
Any member of our group (inside the EEA)
Selected third parties including:
- clients for the purpose of introducing candidates to them;
- candidates for the purpose of arranging interviews and engagements;
- clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
- subcontractors including email marketing specialists, event organisers, payment and other financial service providers
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
- credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Agile Recruitment or all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
The lawful basis for the third party processing will include:
- Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
- satisfaction of their contractual obligations to us as our data processor;
- for the purpose of a contract in place or in contemplation;to fulfil their legal obligations.
Transfer outside the EEA
We may from time to time pass your personal data to clients outside the EEA if you have given your explicit consent for us to do so in relation to a role. No personal information is otherwise stored outside of the EEA
Security and controlling personal data
Agile Recruitment are committed to ensuring that your information is secure. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We take reasonable steps to keep the personal data we possess accurate and to remove incorrect or unnecessary personal data. With respect to the processing of your Personal Data, you will always have the rights as provided by applicable local law. In addition, this Policy provides you the right to know what personal data we hold about you; to request incomplete, incorrect, unnecessary or outdated personal data removed or updated as well as to object to Agile Recruitment’s processing of your Personal Data on compelling legitimate grounds. There may be certain categories of information prescribed by applicable local law that we may lawfully withhold.
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.
Your right of access can be exercised through a subject access request submitted to dataSAR@agilerecruit.co.uk.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to ensure our data is accurate:
- Initial phone call to review & confirm whether the details we hold about you are accurate.
- Prior to introducing you to a client for a vacancy we check that we have accurate information about you
- We keep in touch with you periodically, so you can let us know of changes to your personal data
Agile Recruitment will retain your personal data for 6 years from the date of the last communication with you (email, telephone or otherwise). This is determined on the basis that 6 years is considered to be the average length of time individuals and hiring managers are employed within the industry sectors and organisations we deal with and many candidates can remain ‘dormant’ for long periods of time, only to become ‘actively looking’ when approached with a relevant job opportunity. If there have been no active communications this period, your details will be removed.
For candidates who are ‘engaged under contracts for services’ with our clients, in order to comply with the requirement of financial laws in the jurisdictions that we operate, we will hold your personal data for a minimum of 7 years.
We will remove your personal data from our records once the relevant retention period is reached, or when we are in receipt of a data subject request to do so (if not overridden by lawful requirements). We may archive part or all of your personal data or retain it for our financial records only, deleting all or part of it from our main CRM system.
For the purposes of creating an ‘opt out’ or ‘erasure’ suppression file we may minimise the amount of data we hold down to your name and email address. This will ensure that we do not re-enter your personal data on to our database or communicate with you again but you also have the right to object to this.
The GDPR provides you with the following rights. To:
- 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 remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to 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 in certain formats, if practicable.
- Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org.