Privacy Policy

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:

Prospective and placed Candidates for permanent vacancies;
Prospective and active Client contacts;
Services and Goods Supplier contacts;
Employees, external consultants and temporary workers;
Website Users.

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:

Name;
Age / date of birth;
Gender;
Marital status;
Contact details and postal address;
Education details;
Employment history;
Referees details;
Immigration status (whether you need a work permit);
Nationality / citizenship / place of birth;
Links to your professional profiles available in the public domain e.g. LinkedIn, Xing, Twitter, Viadeo, Facebook, other professional social media or corporate websites.
Information on your interests and needs regarding future employment, both collected directly and indirectly;
Any additional information that you may choose to provide us with;
Any additional information that your referees choose to advise us on;
Any additional information that our Clients may tell us about you, or that we find from other third-party sources such as job sites;
IP address;
Please note that the above list of categories of personal data we collect is not exhaustive. In some jurisdictions, we are restricted from processing some of the above data. In such cases, we will not process the data in those jurisdictions.

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;
Personal data that we receive from other sources;
Personal data that we collect automatically.

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;
Personal data that we receive from other sources;
Personal data that we collect automatically.

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:

You contact us, usually by phone or email;
We contact you via phone, email, LinkedIn or other social media or in person at a trade fair.

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);

Delegate lists at relevant events and trade fairs;
Corporate websites;
Business cards;
Other limited sources and third parties (for example from our Candidates to the extent that they provide us with your details to act as a referee for them).

Personal data that we collect automatically

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.

To continue to provide our services to you.
To maintain our business relationship throughout the lifetime of that relationship, where you are a client or user of our website or services.
To enable us to answer any queries you may have.
To market our products and services to you; to keep you updated on any relevant industry news; to update you on any events, promotions and competitions, reports and any other information we feel may be relevant or of interest to you. You retain the right to unsubscribe from such communications at any time.
To fulfil contractual obligations with you.
To enable the development and marketing of other products and services by company.
To continually improve our customer service efforts and to make our services more valuable to you.
To release personal information to regulatory or law enforcement agencies, should we be required to do so. We will only disclose your information where we are permitted and obliged to do so by law.
We will also seek your consent to collect, hold, use and disclose your personal information for any other purpose not listed above, but will continue to do so only if your permission is given and from which you can withdraw. If we are holding historic data about you or your company that no longer is of use or has any significance, it will be deleted unless you have given consent, or there is a justified legal obligation to retain it.
Only members of our company that need your personal data to carry out their normal duties will be allowed access to the information.

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:

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;
Sub-contractors including email marketing specialists, event organisers, payment and other financial service providers including umbrella companies.
Analytics and search engine providers that assist us in the improvement and optimisation of our site;
Credit reference agencies, insurance companies, 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 data in the following situations:

In the event that we sell or buy any business or assets, we will disclose your personal data to the prospective seller or buyer of such business or assets. If SIMPLEX Recruitment Limited is acquired by a third party, personal data held on its database will be one of the transferred assets.
If we are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our terms of business and other agreements; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
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.

Where we store and process your personal data:

The data that we collect from you may/will be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. SIMPLEX Recruitment Limited will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on a secure database.
As transmission of information via the internet is not completely secure, we cannot guarantee the security of your data transmitted to our site. Although we will do our best to protect your personal data, 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 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:

Prior to making an introduction, we check that we have accurate information about you;
We maintain contact allowing you notify us of any changes to your personal data.

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 function.

YOUR RIGHTS

Under the GDPR, Individuals have the following rights:

The right to be informed how we collect, keep and use your personal data;
The right of access to personal data we hold about you;
The right to rectification of personal data on our records;
The right to erasure of personal data we hold about you which allows you to request your details to be removed or deleted;
The right to restrict processing of your personal data;
The right to data portability, which allows you to request transfer of your personal information to another party;
The right to object for your personal data to be used or processed for specific purposes.
Rights in relation to automated decision making and profiling.

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.