Volaris Exec Recruitment Limited, owner of www.volarisexec.co.uk
People Source Limited(”We”) and its group companies are committed to protecting and respecting your privacy.
The companies within People Source Ltd are:
- People Source Ltd(Registration no: 06995955)
- People Source Consulting Ltd(Registration no: 04389799)
- Volaris Exec Recruitment Ltd(Registration no: 09712773)
This notice applies to all group companies, and 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 person responsible for data protection across all group companies is the Managing Director at People Source Ltd.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (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.
WHO WE ARE AND WHAT WE DO
We are a group of recruitment agencies and recruitment businesses as defined in the Employment Agencies and Employment Businesses Regulations 2003. We also provide managed recruitment services and consultancy services. 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;
We collect information about you to carry out our core business and ancillary activities.
INFORMATION YOU GIVE TO US OR WE COLLECT ABOUT YOU
This is information about you that you provide to us by filling in forms on our sites www.peoplesource.co.uk & www.volarisexec.com or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter 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 site.
The information you give us or we collect about you may include:
- Identity verification such as Passport or Driving Licence
- your name, address, National insurance number, date of birth, gender, private and corporate e-mail address and phone number,
- financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom,
- Links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
Information we collect about you when you visit our website
With regard to each of your visits to our websites we will automatically collect the following information:
- information relating to your visits including, but not limited to, traffic data, location data, weblogs, other communication data and the resources that you access;
- Information that you provide by filling in forms on any of our websites. This includes information provided to us at the time of registering to use any of our websites (where applicable), subscribing to any of our services (where applicable), personalising any of our websites with your preferences or requesting further services;
- Technical Information when you respond to a survey and/or when you report a problem with any of our websites.
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 and personal recommendations. 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, our clients, our business partners, your previous employer, other employment agencies acting on your behalf, Umbrella Companies, reference agencies, professional advisors, companies who provide pre engagement screening services (with your prior consent) as required by our clients. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
PURPOSES OF THE PROCESSING AND THE LEGAL BASIS FOR THE PROCESSING
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, products 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.
To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
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.
If you are a candidate, we may use information held about you:
- to process your application to register with us;
- for matching you with any of our clients and placing you with any of our clients for work assignments;
- to engage you or your company for temporary assignment(s);
- to carry out credit assessments and identity verification, right to work, criminal record and background reference checks;
- to contact you for future work-finding services;
- to process payments for or to you.
In addition, or if you are a client or other third party, we may use information held about you in the following ways:
- to carry out our obligations arising from any contracts entered into between you and us;
- to notify you about changes to any of our services;
- for client service, customer satisfaction, product analysis and market research purposes;
- to ensure that content from our websites is presented in the most effective manner for you and for your computer;
- to provide you with information or services that you expressly request from any of us or which any us feels may interest you, where you have consented to be contacted for such purposes;
- to meet any of our obligations under any applicable laws or regulations;
- carry out any obligations or provide you with any other services, functionality or content which you specifically agree to on any of our websites;
- to help us establish, exercise or defend legal claims.
You may change your marketing preferences at any time by contacting us at GDPR@peoplesource.co.uk.
We do not use your personal information to make automated decisions. All our recruitment activities and ancillary services involve human decision making in the process.
LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
Our Legitimate Business Interests
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. There may be a requirement to carry out pre-engagement and pre-employment screening services (except where we are required to obtain explicit consent to carry out a check). The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts for a period of 6 years. In this timeframe we would look to introduce prospective candidates with relevant employment options and our clients with suitably skilled candidates.
Performance of a contract
We will rely on contract if you are appointed to undertake an assignment at a client (whether as a contractor or temporary worker). We will enter into a contract with your limited company (PSC) or Umbrella Company to engage you for that assignment. Your personal data will be processed as necessary throughout the assignment in order to perform the contract and that you comply with your obligations under the contract. We will also rely on contract if we are negotiating or have entered into a contract to provide services to you or receive services from you or your organisation.
Should we want or need to rely on consent to lawfully process your data we will request your consent verbally, 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. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).
Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular activity at any time by emailing GDPR@peoplesource.co.uk.
We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal obligations. For example, a limited company contractor engaged on an assignment, HMRC requires that we submit regular reports to them detailing the payments which we make to you and other information as set out in The Income Tax (Pay as You Earn)(Amendment No.2) Regulations 2015.
We do not undertake automated decision making or profiling. We do 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.
DISCLOSURE OF YOUR INFORMATION INSIDE AND OUTSIDE OF THE EEA
We may share your personal information with:
Any member of our group both in the EEA and outside of the EEA.
- clients for the purpose of introducing candidates to them;
- Managed service suppliers if our clients have a managed service programme;
- clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
- candidates for the purpose of arranging interviews and engagements;
- Third parties in respect of pre-engagement screening checks;
- HMRC in respect of reporting obligations under The Income Tax (Pay as You Earn)(Amendment No.2) Regulations 2015;
- 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 may 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 People Source Consulting Ltd or substantially all of its 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.
WHERE WE STORE AND PROCESS YOUR PERSONAL DATA
The data that we collect from you may 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. We 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 our secure servers. Any payment transactions will be encrypted using SSL technology. 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 a 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 and that you are happy for us to do so. 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:
- prior to making an introduction we check that we have accurate information about you.
- we keep in touch with you so you can let us know of changes to your personal data.
- we have processes in place to update data records when requested.
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 includes:
- 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.
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 contacting us at GDPR@peoplesource.co.uk.
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 complaintto 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).
A subject access request should be submitted to GDPR@peoplesource.co.uk. No fee will apply once the GDPR comes into force.
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 GDPR@peoplesource.co.uk.
Date of last edit: 24th May 2018.
© 2015 Volaris Exec Recruitment Limited also trading as Volaris Exec Senior Appointments. Registered in England and Wales 09712773 VAT Registered 221 7784 08
Registered office: 1 Georges Square, Bath Street, Bristol, BS1 6BA