1. WHAT IS THE PURPOSE OF THIS DOCUMENT?
Tristone Nash Ltd (the ‘Company’, ‘we’, ‘our’, ‘us’) is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you in accordance with the General Data Protection Regulation (GDPR).
The Company is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
As data controller we are responsible for deciding how we hold and use personal information about you. You have been provided with a copy of this privacy notice because either you wish to use our recruitment services or you have applied for a position with us. It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for.
This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.
It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.
2. Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
3. The Kind Of Information We Hold About You
In connection with your application for work with us, or your registration with us for the use of our recruitment services, we will collect, store, and use the following categories of personal information about you:
· The information you have provided to us in your curriculum vitae and covering letter;
· The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, national insurance number, employment history, qualifications;
· Information regarding your job preferences including role, geographic area and salary;
· A log of our communications with you by email or telephone;
· Immigration status (in relation to the right to work);
· Any information you provide to us during an interview;
· Any information we are given by one of our clients following an interview with you.
We may also collect, store and use the following types of more sensitive personal information:
· Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
· Information about your health, including any medical condition, health and sickness records.
· Information about criminal convictions and offences.
4. How Is Your Personal Information Collected?
We collect personal information about candidates from the following sources:
· You, the candidate.
· Disclosure and Barring Service in respect of criminal convictions.
· Your named referees, from whom we collect the following categories of data: employment history.
· The following data from third parties is from a publicly accessible source: name; email address; employment history.
5. How We Will Use Information About You
We will use the personal information we collect about you to:
· Assess your skills, qualifications, and suitability for applicable role(s).
· Carry out background and reference checks, where applicable.
· Communicate with you about the recruitment process.
· Keep records related to our hiring processes.
· To carry out right to work checks.
· Comply with legal or regulatory requirements.
· For establishing, exercising or defending legal claims.
It is in our legitimate interests to decide whether to appoint you into a particular role (with us or a Company client) since it would be beneficial to our business to appoint someone to that role.
We also need to process your personal information to decide whether to enter into a contract with you.
Once we have received your CV and covering letter and/or your application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for a particular role with us or a particular role that becomes available with one of our clients. If you do, we will decide whether your application is strong enough to invite you for an interview. If we call you for an interview for any role with the Company, we will use the information you provide to us at the interview to decide whether to offer you the role. If you are called for an interview with one of our clients, we may receive feedback from them after the interview. If we (or a client) decide to offer you a role, we may then take up references and/or carry out a criminal record check (depending on whether this is required for the role) before confirming your appointment.
6. If You Fail To Provide Personal Information
If you fail to provide information when requested, which is necessary for us to consider your application/registration (such as evidence of qualifications or work history), we will not be able to process your application/registration successfully. For example, if we require a criminal record check or references for the applicable role and you fail to provide us with relevant details, we will not be able to take your application further.
7. How We Use Particularly Sensitive Personal Information
We may use your particularly sensitive personal information in the following ways:
· We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during interview.
· We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
· For establishing, exercising or defending legal claims.
8. Information About Criminal Convictions
We sometimes recruit candidates into roles which require criminal record checks to be carried out and the information received from such checks being processed by us.
We may be required to carry out a criminal record check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for a particular role.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
9. Automated Decision-Making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
10. Data Sharing
Why might you share my personal information with third parties?
We will only share your personal information with the following third parties for the purposes of processing your application:
· Prospective employers and other recruitment agencies/organisations, to increase your chances of finding employment;
· Third party outsourced IT and document storage providers;
· Marketing technology platforms and suppliers.
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
11. Data Security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
12. Data Retention
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for. Details of retention periods for different aspects of your personal information are available in our retention policy. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
13. Rights Of Access, Correction, Erasure, And Restriction
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
· Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
· 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.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer (see contact details below) in writing.
14. Right To Withdraw Consent
In circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose (e.g. to enable us to inform you of new positions arising), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
15. Data Protection Officer
We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
If you have any questions about this privacy notice, please contact Mr Andy Morgan, the Data Protection Officer, by email: email@example.com.