1. PRIVACY NOTICE
AE 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)
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Act (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within, which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.
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 act in force from time to time the data controller is AE Recruitment, Highland House, Mayflower Close, Chandlers Ford, Eastleigh, SO53 4AR
2. 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;
3. 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 website aerecruitment.ae (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our website, when your details are entered onto 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 website.
The information you give us or we collect about you may include your name, address, private, corporate e-mail address and phone number, financial information, compliance documentation, references verifying your qualifications and experience, 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, Paypal, Twitter, business Facebook or corporate website and any other business relevant documentation.
Information we collect about you when you visit our website.
1. Essential cookies
Some cookies are essential for the operation of our website. For example, some cookies allow us to identify account holders and ensure they can access the account holder only pages. If an account holder opts to disable these cookies, the user will not be able to access all of the content that a subscription entitles them to. This is why these cookies are always switched on as they are classed as essential for this website to function.
2. Performance Cookies
We utilise other cookies to analyse how our visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customising our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or site services that we think will be of interest to you based on your usage of the website
3. Functionality Cookies
We use functionality cookies to allow us to remember your preferences. For example, cookies save you the trouble of typing in your username every time you access the site, and recall your customisation preferences, such as which regional edition of the website you want to see when you log in.
We also use functionality cookies to provide you with enhanced services such as allowing you to watch a video online or comment on a blog.
Where a CV is uploaded, this will be added to our database for use in the introduction of candidates to our clients for the purpose of temporary or permanent engagement.
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, and social media platforms. 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 our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
4. PURPOSES OF THE PROCESSING AND THE LEGAL BASIS FOR THE PROCESSING
Article 6(1)(f) of the GDPR – it says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”
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 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.
• 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.
• 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).
5. OUR LEGITIMATE BUSINESS INTERESTS
Our legitimate interests in collecting and retaining your personal data are described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary work placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
We believe it’s reasonable to expect that if you are looking for employment or have posted your professional cv information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills and work history against any current vacancies that we have.
In order to support our candidates’ career aspirations and our clients’ resourcing needs and to meet our legal obligations to HMRC we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
We want to provide you with tailored job recommendations and relevant articles to read to assist you with your job hunt. We therefore think it’s reasonable for us process your data to make sure that we send you the most appropriate content.
We have to make sure our business runs smoothly, so that we can carry on providing services to candidates like you. We therefore also need to use your data for our internal administrative activities, like payroll and invoicing where relevant.
We have our own obligations under the law. If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.
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.
7. 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 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.
8. DISCLOSURE OF YOUR INFORMATION INSIDE AND OUTSIDE OF THE EEA
We will share your personal information with:
• Any member of our group both within the EEA and outside of 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 AE Recruitment Ltd’s 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.
9. WHERE WE STORE AND PROCESS YOUR DATA
The data that we collect from you will be stored on our own servers and where cloud technology is used this will be within the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted via our banking facilities. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
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.
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. 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 try to ensure our data is accurate:
We shall contact you regularly to ensure that we have an up to date cv and to ensure that your status has not changed.
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data include:
• The nature of the personal data;
• its perceived accuracy;
• our legal obligations;
• whether an interview or placement has been arranged; and
• our recruitment expertise and knowledge of the industry by country, sector and job role.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
10. YOUR RIGHTS
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
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 delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or 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/
Access to information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force). Prior to 25th May 2018 any access request under the Data Protection Act will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
A subject access request should be submitted to email@example.comNo fee will apply once the GDPR comes into force.
11. 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.