PRIVACY NOTICE – DATA PROTECTION POLICY
All organisations that process private data are required to comply with the data processing legislation. As a recruitment business Harris Jones collects and processes both personal data. This Privacy Notice sets out the basis on which Harris Jones Recruitment Ltd will process personal information provided to us.
We have always taken our responsibility in respect of the privacy of personal data very seriously and we will only process personal information as detailed in this notice, unless we inform you otherwise. In order to ensure that the personal data we hold is accurate and up to date, we request that you inform us of any relevant changes to the personal information we hold about you.
Harris Jones Recruitment assists individuals to find work opportunities. In addition we are an employer. Our business is recruitment and we help individuals find work and assist local business’s ‘customers’ with finding suitable employees. This can be directly or supplied by Harris Jones. We also recruit staff to work for us to provide our recruitment services. For the purposes of this privacy notice, our commercial activities and services for individuals and businesses are referred to as ‘recruitment services’, and our actual or potential hiring clients are referred to as ‘customers’.
Our Data Protection Officer is Jacqui Earles-Barrett and can be contacted on (+44) 208 3322622 or firstname.lastname@example.org Our Managing Director is Amanda Harris and can be reached on email@example.com
If you do not wish us to process personal data in accordance with this policy, then please do not provide it to us.
Section A: Candidates wishing to or currently using our recruitment service.
The personal data we collect or receive includes the following:
- Email and other contact details
- Date of birth
- Job history (including information relating to placements through us)
- Educational history, qualifications & skills
- Visa and other right to work or identity information
- Bank details
- National insurance and tax (payroll) information
- Next of kin and family details
- Contact details of referees
- Personal information relating to hobbies, interests and pastimes
- Information contained in references and pre-employment checks from third parties
- Other sensitive personal information such as health records (see ‘Sensitive Personal Data’ section below)
- Your marketing preferences
We may obtain your personal data from the following sources;
- You (CV) , when you attend an interview at our offices, a telephone call and an application or registration form
- A customer
- Other candidates (recommend a friend/referral)
- Online jobsites
- Marketing databases
- The public domain
- Social Media
- At interview
- Notes following a conversation or meeting
- Our websites and software applications
Where you are a candidate and we have obtained your personal data from a third party such as an online job board, it is our policy to advise you of the source when we first communicate with you.
How we will use your personal data:
The processing of your personal information may include:
- Collecting and storing your personal data, whether in manual or electronic files
- Notifying you of potential roles or opportunities
- Assessing and reviewing your suitability for job roles
- Introducing and/or supplying you to actual or potential customers.
- Engaging you for a role with us or with our customers including any related administration e.g. timesheets and payroll
- Collating market or sector specific information and providing the same to our customers
- Sending information to third parties with whom we have or intend to enter into arrangements which are related to our recruitment services
- Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers
- To market our recruitment services
- Retaining a record of our dealings
- Establishing quality, training and compliance with our obligations and best practice
- For the purposes of backing up information on our computer systems
Harris Jones may hold personal data on individuals for the following purposes:
- Staff administration
- Advertising, marketing and public relations
- Accounts and records
- Administration and processing of candidates personal data for the purposes of providing work-finding services, including processing using software solution providers and back office support
- Administration and processing of customers personal data for the purposes of supplying/introducing candidates
- In accordance with the Conduct of Employment Agencies and Employment Business Regulations 2003 for verification of identity.
Section B. Legal bases for processing
Harris Jones will only process personal data where it has a legal basis for doing so. Before transferring personal data to any third party (such as past, current or prospective employers, suppliers, customers and intermediaries such as umbrella companies, persons making an enquiry or complaint and any other third party (such as software solutions providers and back office support) Harris Jones will establish that it has a legal reason for making the transfer.
Timescale and consent for holding personal data
Harris Jones intends to hold records for two years unless otherwise instructed by our candidate or client. You can ask us to remove your data at any time providing it is within HMRC compliance and any other law or regulation.
We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you apply for a specific role you may have consented to our processing of the data that has been provided for the purpose of progressing your application and considering your suitability for that role. In other cases you may have provided your written or verbal consent to the use of your data for a specific reason.
Legitimate business purposes
We may also collect and use personal information when it is necessary for other legitimate purposes, such as to help us conduct our business more effectively and efficiently – for example, for General IT security management, accounting purposes or financial planning. We may also process your personal information to investigate violations of law or breaches of our own internal policies.
We may also use your personal data where we consider it necessary for complying with laws and regulations, including collecting and disclosing employee personal information as required by law (e.g. for tax, health and safety, anti-discrimination).
Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our consideration of your suitability for a job role. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health, which include:
- Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
- establishing compliance with contractual obligations with customers or suppliers
- addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
- protecting our reputation
- maintaining a backup of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
- evaluating quality and compliance including compliance with this privacy notice
- determining staff training and system requirements
- Using your personal data to:
- assess suitability and contact you regarding potential opportunities and/or our services
- collate market information or trends including providing analysis to potential or actual customers
- source potential opportunities or roles as part of our recruitment services
- personalise your experience and our offering, whether via our website or otherwise
This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes.
Section C. Information from third parties
Part of our business activity involves researching information relating to individuals for the purposes of filling job roles. This may include obtaining personal data from online sources, for example we may obtain information from social media sites such as LinkedIn and job boards, some information being publicly available but others being from sites or providers to which we subscribe.
In addition, we make certain personal data available to third parties who provide services to us. We do so on a “need to know basis” and in accordance with applicable data protection and data privacy laws.
For example, some personal data will be available to our employee benefit plans service providers and third party companies who provide us with employment law advice, health and safety support, payroll support services (David Howard Accountants) expenses, tax and travel management services. In addition to clients who have approached us with a suitable vacancy or opportunity and other agents we work with who have agreed to our policy (after we have permission from you).
Transfers to other third parties
We may also disclose personal data to third parties on other lawful grounds, including:
- To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process
- In response to lawful requests by public authorities (including for national security or law enforcement purposes)
- As necessary to establish, exercise or defend against potential, threatened or actual litigation
- Where necessary to protect the vital interests of our employees or another person
- In connection with the sale, assignment or other transfer of all or part of our business; or
- With your freely given and explicit consent
Where you have notified us that you do not want us to provide you with services, we shall discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our recruitment services, any processing will be in accordance with this privacy notice.
Section D. Sensitive Personal Data (SPD)
Sensitive personal data (‘special categories of personal data’ under the General Data Protection Regulation) includes any information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, genetic data, biometric data for the purposes of unique identification, trade union membership, or information about your health/sex life. Generally, we try not to collect or process any sensitive personal information about you, unless authorised by law or where necessary to comply with applicable laws. In some circumstances, we may need to collect some sensitive personal information for legitimate employment-related purposes: for example:
- data relating to your racial/ethnic origin, gender and disabilities for the purposes of:
- equal opportunities monitoring;
- to comply with anti-discrimination laws; and
- for government reporting obligations;
- data relating to your physical or mental health to:
- provide work-related accommodations,
- health and insurance benefits to you and your dependents; or
- To manage absences from work.
We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information include:
- Individuals, hirers and other third parties necessary for the provision of our Recruitment Services
- Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
- Parties who process data on our behalf, which may include
- outsourced payroll providers
- IT support
- storage service providers including cloud
- Background screening providers
- Legal and professional advisers
We will process your personal data in the context of our dealings with the third party for whom you work and as part of our recruitment services. Processing may include:
- Collecting and storing your personal data, whether in manual or electronic files
- Using the data to communicate with you
Section E Your rights
We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you have provided your contact details in order that we may use these to provide you with details of our services you may have consented to our processing of the data for that purpose. In other cases you may have provided your written or verbal consent to the use of your data for a specific reason, for example references.
You may withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.
The candidate or customer has the right to ask the company to rectify any inaccurate or incomplete personal data concerning an individual.
If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to rectify the personal data unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold – however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred
You may exercise the rights available to you under data protection law as follows:
- The right to be informed.
- The right of access.
- The right to rectification.
- The right to erasure.
- The right to restrict processing.
- The right to data portability.
- The right to object.
- Rights in relation to automated decision making and profiling.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. You can read more about these rights at:
To exercise any of these rights, please contact Jacqui Earles-Barrett.
Issues and complaints
We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This notice was drafted with clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed.
If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office in their capacity as the statutory body which oversees data protection law – www.ico.org.uk/concerns.
Updates to this notice
This notice may be updated periodically to reflect any necessary changes in our privacy practices. In such cases, we will inform you by companywide email. We encourage you to check this notice periodically to be aware of the most recent version.
Please address any questions or requests relating to this notice to Jacqui Earles-Barrett or Amanda Harris. Harris Jones Recruitment Ltd, 1A Sheen Road, Richmond, Surrey. TW9 1AD. firstname.lastname@example.org Telephone; 020 8332 2622
Group companies & transfer
In the event of a sale, merger, liquidation, receivership or the transfer of all or part of our assets to a third party, we may need to transfer your information to a third party. Any transfer will be subject to the agreement of the third party to this Privacy Notice and any processing being only in accordance with this Privacy Notice.
Data Security and Confidentiality
It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not accessible to unauthorised third parties in line with contemporary practice.
This does not affect your right to make a complaint to the Information Commissioner’s Office.