CSA Recruitment (The Company) is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.
You may give your personal details to the Company 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. The Company 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 the terms of the following statement.
- Collection and use of personal data
a) Purpose of processing and legal basis
The Company has collected/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. The legal bases we rely upon to offer these services to you are:
- Legitimate interest
- Legal obligation
- Contractual obligation
b) Categories of data
The Company has collected the following personal data on you:
- Date of birth
- Contact details, including telephone number, email address and full postal address
- Experience, training and qualifications
- Salary / Pay Details
- National insurance number
Sensitive personal data
- Disability/health condition relevant to the role
- Criminal conviction
c) Legitimate interest
Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
- Fraud detection and prevention (crime prevention)
- Compliance with foreign law, law enforcement, court and regulatory bodies’ requirements
- Industry watch-lists and industry self-regulatory schemes
- Information, system, network and cyber security
- Employment/work-finding data processing
- General Corporate Operations and Due Diligence
- Product development and enhancement
- Communications, marketing and intelligence
d) Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients:
- To process your data internally within the Company to provide you with work and work-finding services
- To process your data on a computerised database with access by the named provider above to provide you with work and work-finding services
- To process with or transfer your personal data to the named client/s or third parties above in order to provide you with work and work-finding services
- To process your data using automated decision-making processes. I am aware for what purpose it is being carried out; the logic involved; the significance and the envisaged consequences of such processing; your right to express my views and to contest the decision.
- To process your data with the named third parties above for audits and investigations that the Company is complying with laws and obligations.
e) Statutory/contractual requirement
Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:
- Not able to provide you with work and work-finding services
- Overseas Transfers
The Company may transfer only the information you provide to us to countries outside the European Economic Area (“EEA”) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
- Data retention
The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year 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.
Where the Company has obtained your consent to process your personal and sensitive personal data (1.b), we will do so in line with our retention policy (a copy of which is attached). Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.
- Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you;
- The right of access to the personal data the Company 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 the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting the Company that I wish to do so and completing the appropriate Withdrawal of Consent to Process Personal Data form.
- Source of the personal data
The Company sourced your personal data/sensitive personal data by the following means:
- Job boards
- Social media
- Word of mouth/referrals
- Registration form
- Jobs fair
This information came from a publicly accessible source.
- Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Data Protection Officer, Llanelli Gate Business Park, Llanelli, SA14 8LQ, 01554 746746, firstname.lastname@example.org
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.