| Company Name: | Prince Personnel Limited (‘the Company’) |
| Contact details: | Maria Sandford, Data Protection Co-ordinator Tel: 01952 299 844 Email: maria.sandford@prince-personnel.co.uk |
| Document title: | Privacy Notice (Work-seekers) |
| Topic: | Data protection |
| Date: | 11th May 2018 |
| Version: | 2 |
The Company is a recruitment business which provides work-finding and career management services. 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 or other on-line referrers of work-seeker information. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services, information relating to roles relevant to you and/or career management services we will only use your personal data in accordance with the terms of the following statement.
1. Collection and use of personal data
The table set out in the Schedule summarises the information we collect and hold, how and why we do so, how we use it and with whom it may be shared.
We may also need to share some of the categories of personal information set out in the schedule with other parties, such as external contractors and our professional advisers and potential purchasers of some or all of our business or on a re-structuring. Whenever reasonably practicable, information will be anonymised. In any event, the recipient of the information will be bound by confidentiality obligations.
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.
2. 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.
3. Data Retention
The Company will retain your personal data only for as long as is necessary, as indicated in the Schedule.
4. 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.
If you wish to exercise any of the above rights, please contact our Data Protection Co-ordinator.
5. Complaints or queries
If you have any queries or concerns about this privacy notice or any of the procedures set out in it please contact our Data Protection Co-ordinator.
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.
Schedule
Part 1
Work-seekers for positions with third parties and/or for temporary assignments through the Company
| The information we collect | How we collect the information | Why we collect the information | How we use and may share the information | Retention period |
|---|---|---|---|---|
| Your name, contact details (ie address, home and mobile phone numbers, email address) | From you and job boards | To enter into/perform our contract with youLegitimate interest: to enable a fair recruitment process to be carried outLegitimate interest: to enable applications to progress, interviews to be arranged and you to be informed of the outcome at all stagesLegitimate interest: to maintain work records and good practice | To enter into/perform our contract with youTo inform clients of ours who are seeking workers of your availabilityTo facilitate contact with you to progress applications, arrange interviews and inform you of the outcome | 40 years* |
| Your National Insurance number and your date of birth | From you | To perform our contract with you, including, if we assign you to a temporary position, making payments to you and providing benefitsLegitimate interests: to maintain worker or other records and to comply with legal, regulatory and corporate governance obligations and good practice | To help correctly identify youIf we assign you to a temporary position, to ensure you receive the correct pay and benefitsIf we assign you to a temporary position, information shared with HM Revenue & Customs (HMRC) | 40 years* |
| Details of your emergency contacts (ie name, relationship and home and mobile phone numbers) | From you | To perform our contract with youLegitimate interest: to maintain work records and good practice | To perform our contract with youTo facilitate contact with youTo notify emergency contacts in the event of death or serious injury or ill-health at meetings with you or at work | If we do not place you in a position with a third party or assign you to a temporary position, 3 years; or if we do, 7 years from when you are last placed or from the end of the last assignment, whichever is the later |
| Details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests | From you, in your CV, the completed application form and interview notes (if relevant) | Legitimate interest: to enable a fair recruitment processLegitimate interest: to enable an informed decision in respect of shortlist for interview and / or recommendation for a position or assignment | To make, and to enable clients of ours to make, informed recruitment decisions | 40 years* |
| Information regarding your academic and any professional qualifications | From you, from your education provider, from the relevant professional body | Legitimate interest: to verify the qualifications information provided by you | To make, and to enable clients of ours to make, informed recruitment decisions | 40 years* |
| Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information | From you and, where necessary, the Home Office | To enter into/perform our contract with youTo comply with our legal obligationsLegitimate interest: to maintain records | To carry out right to work checksInformation may be shared with our clients who are seeking workers and / or the Home Office | If we do not place you in a position with a third party or assign you to a temporary position, 3 years; or if we do, 7 years from when you are last placed or from the end of the last assignment, whichever is the later |
Part 2
Work-seekers for temporary assignment only
| The information we collect | How we collect the information | Why we collect the information | How we use and may share the information | Retention period |
|---|---|---|---|---|
| Information from references obtained about you from previous employers and/or education providers | From previous employers and/or education providers | Legitimate interest: to enable a fair recruitment processLegitimate interest: to enable an informed decision in respect of shortlist for interview and / or recommendation for a position or assignment | To make, and to enable clients of ours to make, informed recruitment decisions | 40 years* |
| Details of salary and benefits, bank/building society and tax information ☐ | From you | To perform our contract with you, including making payments to you and providing benefitsLegitimate interests: to maintain worker or other records and to comply with legal, regulatory and corporate governance obligations and good practice | To ensure you receive the correct pay and benefitsInformation shared with HM Revenue & Customs (HMRC) | 7 years |
| Details of your pension arrangements, and all information included in these and necessary to implement and administer them ☐ | From you and our pension administrators, Now Pensions | To perform our contract with youTo comply with our legal obligationsLegitimate interests: to maintain worker records and to comply with legal, regulatory and corporate governance obligations and good practice | To comply with our auto-enrolment pension obligationsInformation shared with our pension administrators, Now Pensions, and with HMRC | 7 years |
| Details of your time and attendance records | From you and clients of ours to whom you are assigned | To perform our contract with youLegitimate interest: to monitor, manage and record absences | For payroll and worker administration and to monitor attendanceInformation shared with clients of ours with whom you are placed | 7 years |
| Information in your sickness and absence records (including sensitive personal information regarding your physical and/or mental health) ☐ | From you, from your doctors, and from medical and occupational health professionals we engage | To perform our contract with you including regarding any work-related benefitsTo comply with our legal obligationsLegitimate interests: to maintain records and to comply with legal, regulatory and corporate governance obligations and good practice, to ensure safe working practices | To maintain records, to administer sick pay entitlement, and to follow our policiesTo comply with our legal obligations to youInformation shared with your doctors, with medical and occupational health professionals we engage and, if relevant to any assignments, to the client(s) of ours to which you are assigned | 7 years |
| Details in references about you that we give to others | From your personnel records, our employees and clients of ours with whom you are assigned | To perform our contract with you | To perform our contract with you | 7 years |
You are required (by law or under the terms of your contract with us, or in order to enter into your contract with us) to provide the categories of information marked ‘☐’ above to us to enable us to verify your right to work and potential suitability for positions and, in the case of temporary assignments through the Company, to pay you, to provide you with relevant benefits and to administer statutory payments such as statutory sick pay (SSP) and pension auto-enrolment. If you do not provide this information, we may not be able to place you with clients who are seeking workers or, in the case of work-seekers seeking temporary assignments, engage you, make payments or provide benefits.
* Please note that it is our usual practice to retain certain personal data long term in order that we might contact you to obtain up to date information regarding your work-seeking and/or career management requirements and notify you of work opportunities from time to time. Any such personal data is stated to be subject to a 40 year retention period. However, consistent with your rights under point 4 of the Privacy Notice, you can object to this, in which case we will retain the relevant data until later of (i) the next working day after you communicate your objection, (ii) the date 7 years from the last date that we provided work-finding services for you and (iii) the date 7 years after your last temporary assignment through us.