As a recruitment business, we collect and processes personal data (including sensitive personal data) in order to provide work finding services. In doing so, the company acts as a data controller. The Company must have a legal basis for processing your personal data and we will only use your personal data in accordance with this privacy statement.
We will make it clear in this policy how we collect and use that data. Depending on the nature of the data, we may be required by law to keep this data for different periods of time. However, we will not keep your data for longer than is necessary and we will not collect data that we don’t need. We will endeavour to only communicate relevant information to you and we will not send you spam or sell your data to any 3rd party.
This policy sets out how the Company implements the Data Protection Laws. Our supervisory authority is the Information Commissioner’s Office (ICO).
Company Name: Carnegie Consulting Ltd. (“The Company”)
Contact Details: 25 Gerrard Street, London, W1D 6JL
Company number: 05661997
2. Collection and use of personal data
a) Purpose of processing and legal basis
The Company 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. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.
In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
The legal bases we rely upon to offer our work-finding services to you are:
- Your consent
- Where we have a legitimate interest
- To comply with a legal obligation that we have
- To fulfil a contractual obligation that we have with you
b) Legitimate interest
This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
- Managing our database and keeping work-seeker records up to date
- Providing work-finding services to you and our clients
- Contacting you to seek your consent where we need it
c) Statutory/contractual requirement
The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements). Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us personal data we need to collect we may not be able to continue to provide work-finding services to you.
d) Recipient/s of data
The Company may process your personal data and/or sensitive personal data with the following recipients:
- Clients (whom we may introduce or supply you to)
- Former employers whom we may seek references from
- Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to
- Other recruitment agencies in the supply chain
- Our IT and CRM service providers
- Any Government or Law Enforcement agency should we be legally required to do so
3. Categories and sources of data
a) Categories of personal data:
The company has collected some or all of the following personal data on you:
- Contact Information such as address, mobile number and email
- National insurance number
- Education and employment history
- Nationality (through right to work check)
- Where a CV has been provided, any additional information contained within
- Relevant health information such as whether you have a disability
- Criminal conviction
b) Sources of personal data
The Company sourced your personal data by one of the following means:
- Provided directly to The Company by the data subject
- A job board or professional networking site
- A 3rd party provider who the data subject has engaged with in the first instance
- Referral from somebody known to the data subject
- Cookies listed in section 7
4. Overseas Transfers
The Company may transfer 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.
5. Data retention
The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after 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. This is currently 3 to 6 years.
6. 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
- The right to withdraw consent at any time
Where you have consented to the Company processing your data you have the right to withdraw that consent at any time by contacting the company. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.
There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
We may obtain data about you from cookies. These are are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.
We use the following cookies:
These cookies allow us to count page visits and traffic sources so we can measure and improve the performance of our site, using a service provided by Google Analytics.
Cookie created by the Wordfence security plugin which shows information about your general geographic location. This is used for security purposes.
Cookie created by the Wordfence security plugin, used to protect the website from online attacks.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
Most web browsers allow some control of most cookies through the browser settings. Please note that in a few cases some of our website features may not function if you remove cookies from your browser.
8. Log files
We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
9. Links to external websites
The Company’s website may contains links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.
10. Sale of business
If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
11. Data Security
The Company takes every precaution to protect our users’ information including firewalls, browser certification technology, encryption, limited access, use of passwords etc.
Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information.
The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet. If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered.
If you have any questions about the security at our website, you can email firstname.lastname@example.org
12. Changes to this privacy statement
We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.
13. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact email@example.com.
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.
14. Annex A
a) The lawfulness of processing conditions for personal data are:
- Consent of the individual for one or more specific purposes.
- Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract.
- Processing is necessary for compliance with a legal obligation that the controller is subject to.
- Processing is necessary to protect the vital interests of the individual or another person.
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
- Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data, in particular where the individual is a child.
b) The lawfulness of processing conditions for sensitive personal data are:
- Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited by EU or Member State law.
- Processing is necessary for carrying out data controller’s obligations under employment, social security or social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental rights and interests of the individual.
- Processing is necessary to protect the vital interests of the individual or another individual where the individual is physically or legally incapable of giving consent.
- In the course of its legitimate activities, processing is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the consent of the individual.
- Processing relates to personal data which are manifestly made public by the individual.
- Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
- Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law which shall be proportionate to the aim pursued, respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the individual.
- Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional and subject to the necessary conditions and safeguards.
- Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy.
- Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.