INTRODUCTION
This Privacy Policy provides details what we do with your personal data, whether we have contact with you as a client, candidate, supplier or in any other form related to the nature of our business and its activities. It explains our methods of collecting, using and processing your personal data and compliance with our legal responsibilities to you. Your privacy is our top priority and we are fully committed to protecting and safeguarding your data privacy rights.
Our Privacy Policy may be occasionally amended and therefore we advise and encourage you to visit this page and review the details to stay up to date. In the event of any changed being made to the Policy, appropriate notifications will be posted in this section. For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679)) (the “GDPR”), your rights under the GDPR are set out in this notice, which come to force on 25th May 2018.
WHAT PERSONAL DATA DO WE COLLECT?
As a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Business Regulations 2003, we collect personal data of the following types of people, which allows us to conduct our business:
CANDIDATE DATA: If we work with you as a Candidate, depending on the relevant circumstances and applicable local laws and requirements, we collect some or all of the information listed below, which allows us to provide you with suitable employment opportunities, matching your specific requirements and expectations:
CLIENT DATA: Being our Client means that we need to collect and use information about you or individuals at your organisation to providing you with our recruitment services. However, the data collected about Clients is typically limited to general contact details such as name, telephone number, email address, which allows us communication with you.
SUPPLIER DATA: Being our Supplier means that we collect basic data about relevant individuals at your organisation, which enables communication with your company. This typically includes name, telephone number, email address as well as Suppliers’ bank details.
WEBSITE USERS DATA: We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, and the times that our website is most popular.
HOW DO WE COLLECT YOUR PERSONAL DATA?
CANDIDATE DATA: We collect Candidate personal data in three primary ways:
Personal data that you provide to us as a Candidate
This is information about you provided to us by communicating with us in person, by telephone, e-mail, using our website or otherwise. It includes information you provide when you enter our database, subscribe to our services, fill out an online contact form, visit our website, attend our events, participate in discussion boards or other social media functions and when you report a problem with our site.
Personal data that we receive from other sources
This is information we obtain about you from other sources such as LinkedIn, Xing, Viadeo, corporate websites, job board websites, online CV libraries, business cards, recommendations or referrals that we may receive about you. In such event, you will be duly informed by receiving this privacy notice, within a maximum of 30 days of collecting the data, of the fact that we hold your personal data, 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.
Occasionally, we work with third parties including business partners, sub-contractors, advertising and publishing companies, market intelligence providers and professional advisors. We may receive information about you from them for the purposes of our recruitment services and general business purposes.
Personal data we collect automatically
To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.
CLIENT DATA : We collect Client personal data in three ways:
Personal data that we receive directly from you as a Client
We collect data directly from you as our active or prospective Client in two ways:
Personal data we receive from other sources
Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:
Third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us);
Personal data that we collect automatically
To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.
WEBSITE USERS: When you visit our website, there is certain information that we may automatically collect, regardless of your decision to use our services or not. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via the website, for example by using the online contact form.
WHAT DO WE USE YOUR PERSONAL DATA FOR?
As a recruitment consultancy, our main purpose is to source suitable Candidates to match our Clients’ vacancies. This section provides details of various ways in which we may use and process your personal data for recruitment purposes, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
We may use your personal data for the above purposes as deemed necessary for our legitimate interests. If you are unsatisfied about this, you have the right to object and you may contact us at any time about your personal data rights by emailing emilia@simplexrecruitment.com . Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements.
HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
We will delete your personal data from our database if we have not had any meaningful contact with you for six years or for such longer period as we believe in good faith that the law or relevant regulations require us to keep your data. After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
For purpose of clarity, “meaningful contact” means, for example, communication between us in either verbal or written form, or where you are actively engaging with our online services. If you are a Candidate, we will consider there to be meaningful contact with you if you submit your updated CV onto our website or request any of our online services. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.
LEGITIMATE BUSINESS INTERESTS
As a recruitment business and recruitment agency we introduce candidates to clients for specific vacancies. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process. To allow us to offer appropriate recruitment services to our clients and candidates, we require a database of personal data containing historical information as well as current staffing requirements. In order to undertake our business, we need to record the personal data of prospective candidates and client contacts.
CONSENT
In the event we 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 consent is required for and keep a record of this on our database. Where consent is the lawful basis for our processing, you have the right to withdraw your consent to this particular processing at any time.
DISCLOSURE OF YOUR INFORMATION INSIDE AND OUTSIDE OF THE EEA
We will share your personal information with selected third parties, to include, but not limited to:
We will disclose your personal data in the following situations:
Where we store and process your personal data:
RETENTION OF PERSONAL 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 and that you are happy for us to do so. Accordingly, we run data check procedures 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:
The criteria we use to determine, whether we should retain your personal data include:
YOUR RIGHTS
Under the GDPR, Individuals have the following rights:
You can exercise any of your rights at any time by contacting us at emilia@simplexrecruitment.com . You have the right to make a complaint to a supervisory body, which in the UK is the Information Commissioner’s Office (www.ico.org.uk).
ACCESS TO INFORMATION
The GDPR gives you the right to access information we hold about you. We also encourage you keep us updated on any relevant changes in your circumstances in order to maintain an accurate recordinf. You can exercise your right of access in accordance with the GDPR. A subject access request should be submitted via emilia@simplexrecruitment.com .
PERSONAL DATA BREACH
The GDPR requires us to notify any personal data breach to the applicable regulator and, in certain instances, to you. We have put in place procedures to deal with any suspected personal data breach and will notify you or any applicable regulator, where we are legally required to do so.
If you know or suspect that a personal data breach has occurred, do not attempt to investigate the matter yourself. You should preserve all evidence relating to the potential personal data breach and immediately contact Emilia Furdal in the first instance via email emilia@simplexrecruitment.com or telephone 0044 1789 266 660.
CONTACT
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to emilia@simplexrecruitment.com.