HL Services (London) Ltd (“The Company”) is committed to protecting the privacy of our clients, candidates and users of our websites. This notice relates to candidates or potential candidates.
The Company means HL Services (London) Ltd (company number 9204063), its subsidiaries, its associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group) and the brands these companies use.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation replacing the Data Protection Regulation (Directive 95/46/EC) The Regulation harmonises data protection legislation across EU member states.
The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.
You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you, the Company will only use your personal data in accordance with the terms of the following statement, once the GDPR becomes law on 25th May 2018.
1) Collection and use of personal data
a) What type of data the company collects
The Company is a recruitment business and an employment business, which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller. The Company collects the personal data of the following types of people to allow it to undertake its business:
- Potential and live client contacts
- Potential candidates and those placed in temporary, contract, or permanent or roles
- Employees, consultants, temporary and self-employed workers
- Supplier contacts
The information you give the Company or it collects about you may include:
Who you are and how to contact you
Name, address, postcode, private and corporate e-mail addresses, telephone phone numbers
Information about your professional life
CV, photograph, employment details and preferences, professional profiles available in the public domain such as Twitter, LinkedIn, or a corporate website.
Compliance and due diligence
Financial information, documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, tax and national insurance information to pay you if you are a temporary worker, contractor or self-employed person.
Information obtained from other sources
This is the information we may obtain from sources such as LinkedIn, or other social media sources, corporate websites and job boards. In this case we will inform you, by sending you this privacy notice, within 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from, whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
b) Purposes of the processing and the legal basis for the processing
The Company uses information held about you in the following way to provide job finding and complementary services to our candidates.
The Company’s principal service is the introduction of candidates to its clients for temporary or permanent work assignments. This encompasses meeting candidates’ current needs and supporting them through the course of their careers. To do this, the Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services and ancillary services such as training.
The principal legal basis for the processing of personal data is our legitimate business interests, described below.
The Company will also rely on the following bases for specific uses of data:
- legal obligation (for example to record your right to work in the UK)
- contractual obligation (for example to process your information to pay you, or to provide your personal information to a client)
- consent (for example your consent for your details to be passed to a client for a potential role)
c) Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data are as follows:
The Company introduces candidates to clients for permanent, temporary and contract roles, thereby furthering the careers of those candidates and providing an essential service to its clients. The processing of personal data relating to our candidates and our client contacts is critical to this process.
The Company maintains databases of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain and develop its business, the Company also records the personal data of potential candidates and client contacts.
To deliver its principal services, as well ancillary offerings, the Company contacts candidates on a regular basis, via various means such as email, phone, job alerts and other relevant notifications.
2) Disclosure of your information inside and outside of the European Economic Area (EEA)
The Company may share your personal information with:
- Any members of its group, whether in the EEA and outside of the EEA.
- Candidates (if you are a client) to arrange interviews and engagements.
- Clients to introduce candidates to them.
- Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract the Company enters into with them or you.
- Subcontractors including email marketing specialists, event organisers, payment and other financial service providers.
- Organisations that assist the Company in the improvement and optimisation of its websites.
- Organisations that may assist the company in confirming your suitability for a role.
- The buyer, in the event all or part of the company is sold.
- Organisations where the Company has a duty to disclose or share your personal data in order to comply with any legal obligation.
- Organisations that may assist the company in enforcing its contractual rights or meeting its contractual responsibilities.
The lawful basis for the third-party processing will include:
- Their legitimate business interests in processing your personal data, for example in recruiting new permanent or temporary workers.
- Satisfaction of their contractual obligations to the Company as a data processor;
- For the purpose of a contract in place or in contemplation;
- To fulfil their legal obligations.
Storing and processing your personal information
The Company may transfer only the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein
3) Retention of your data
The Company will retain your personal data only for as long as is necessary for its legitimate business interests or as required by contractual obligations or law. Different laws require different retention periods.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
Where the Company has obtained your consent to process your personal and/or sensitive personal data, we will do so in line with our retention policy. Upon expiry of that period, the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal and/or sensitive personal data.
Our current retention notice will be available upon request from 25th May 2018.
4) Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you;
- The right of access to the personal data the Company processes on you;
- The right to rectification of your personal data;
- The right to erasure of your personal data in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on a public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
Should you wish to exercise any of the above rights, you may do so by contacting the following email address: firstname.lastname@example.org
5) Links to third party websites
The company’s websites may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that the Company does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
6) Changes to the Company’s privacy notice
Any changes The Company makes to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail.
7) Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact the following email address: email@example.com
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to