Contracts Consultancy LTD (”We”) are committed to protecting and respecting your privacy.
Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group).
This notice 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 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.
For the purposes of data protection legislation in force from time to time the data controller is Contracts Consultancy Ltd of 162 – 164 Upper Richmond Road, London, SW15 2SL. Our nominated representative is Jonathan Cox.
Who we are and what we do
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). 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 give us by filling in forms on our site www.cclglobal.com (our site) 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 your name, address, 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, curriculum vitae and photograph, 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 site we will automatically collect the following information:
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
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, personal recommendations. In this case we will inform you, by sending you a link to 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, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors and others. 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.
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.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent
may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. 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.
Should we want or 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 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.
Other Uses we will make of your data:
• Use of our website;
• to notify you about changes to our service;
• to ensure that content from our site is presented in the most effective manner for you and for your computer.
We will use this information:
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We do/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 will share your personal information with:
Any member of our group both in the EEA and outside of the EEA.
Selected third parties including:
• 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;
• subcontractors including email marketing specialists, event organisers, payment and other financial service providers.
• advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
• analytics and search engine providers that assist us in the improvement and optimisation of our site;
• credit reference agencies, 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 will 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 Contracts Consultancy 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:
• our website enables you to manage your data and to review whether the details we hold about you are 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 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 email@example.com.
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 complaint to 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 firstname.lastname@example.org. No fee is applicable once the GDPR has come 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.
Grounds for Processing: Legitimate Business Interest
Legitimate Interest to Register & Store Personal Details: CCL is in the Business of finding Careers & Contracts for Candidates, and Candidates & Contractors for Clients, which is a legitimate commercial purpose, for which the use of Personal Data of Clients and Candidates to make Introductions and arrange Placements is necessary. It is reasonable to expect that an individual who has sent their CV in response to an advert, or who has uploaded their CV to a job board, or whose career details are downloadable from a social networking site, expects our processing of their data. CCL will do this in a balanced way that does not override their interests or cause unjustified harm.
Explicit Consent to Storing Personal Data: Legitimate Business Interest justification is adopted
Explicit Sharing Consent: In accordance with both GDPR and The Conduct of Employment Agencies and Employment Business Regulstions 2003, for a CV to be shared with a Client / Third Party, Candidates must always give Explicit Sharing Consent, on the Phone or via Email, in advance. Candidates may give General Sharing Consent, if they Consent to their CV to be shared with any Relevant Client or Job at CCL’s discretion. If General Sharing Consent is not given, Specific Sharing Consent must be given in relation to a specific Client (by Name (or by description if the Client has asked to remain Confidential)), or a specific Job; in giving Specific Consent, Candidates agree that they will be represented by CCL with regard to that Client or Job. We will record General Sharing Consent or Specific Sharing Consent by sending a Confirmation of Representation email, in case there is a misunderstanding; candidates do not need to reply to this – by definition they have already given their Explicit Consent. No CV will be sent to a Client / Third Party without Explicit Consent.
Contract Grounds for Processing: Under the Conduct of Employment Agencies and Employment Businesses Regulations 2003 CCL has a statutory obligation to retain data for at least a year after its creation and at a least a year after any work-finding services,including a contract for services.
Privacy and Electronic Communications Regulations (PECR): CCL markets Careers & Contracts to Candidates, and Candidates & Contractors to Clients. CCL’s legitimate interets mean our marketing activities use people’s data proportionately, with minimal privacy impact, and all such communications offer an opt-out / unsubscribe option.
Your rights: You have rights to your data: subject access request, plus rectify, delete, restrict data, withdraw consent, complain to the ICO
Controller: CCL is the Data Controller of the personal data of candidates that it processes. CCL will only act as a Processor of personal data on behalf of clients when we are notified by the client the details of the personal data and the processing.
CCL ICO Registration: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr
Controler of Personal Information: Jonathan Cox; email@example.com
Data Protection Officer: N/A
GDPR Fair Processing Policies
Registration: within 1 month of collecting Personal Data (e.g. CV) CCL will inform you that your Personal Data has been collected
Source: CCL sources CVs from Job Boards, Social Networking sites, Referrals, Spontaneous or Adverts; we cannot specify individually, but can respond to specific requests
Keeping: if a candidate sends us a CV, or we download it from a Job Board or other site, we do store it for consideration for future jobs
Remove: if you wish you Personal Data to be removed, please contact the Data Controller firstname.lastname@example.org
Limitation: we will only collect the data we need
Dates: Creation Date, Updates and Date of Last Contact (via Email, Phone or Meeting) are recorded
Deleted: Deleted data will be Archived and only accessible to the Data Controller, as evidence that it has been deleted
Security: To Certified Privacy Seal status with the True Ultimate Standards Everywhere (www.truste.com) online privacy seal (https://en.wikipedia.org/wiki/TRUSTe)
Breach: we will notify the Information Commissioners Office and the Subjects
Transparency: Everyone can access the Personal Data we hold for them, keep it up to date, and request Removal, directly via the CCL Career Portal
Sharing: when Explicit Consent has been given, CCL will share Personal Details with prospective Clients
Sensitive: CCL does not store any Sensitive Data
For us to continue recruitment services to you, we will retain your details as follows (unless you ask us not to):
• you have worked via us on contract – 6 years
• you have experience in Sectors, Disciplines or Skills defined as relevent to our business taxonomy – 6 years
• your experience is not relevant to our business but your CV has been shortlisted for a client vacancy – 2 years
CCL’s Retention Policy applies to our own storage of your Personal Details, as a Data Controller; if we have received your CV from a Job Board or Social Networking site, your CV will comply with our Retention Policy; accordingly, you must also advise us, as well as the other party, if you wish to Remove your details from us.
After we Register your details, we will Delete them as follows:
• you do not have experience in Sectors, Disciplines, Skills or Territories relevant to our business taxonomy – 6 months
• you reach State Pension Age – we will write to you asking if you wish to remain registered – 6 months
• you have not replied to communications from us more than 6 times – 6 months
• we have not had any commercial reason to communicate with you – 6 years
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to email@example.com