Henry Blue Ltd is a recruitment business which provides work-finding services to its clients and work-seekers. Henry Blue Ltd 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 job 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. We will only use your personal data in accordance with the terms of the following policy.
This Privacy Policy explains what we do with your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to work finding services, or you are visiting our website.
It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
This Privacy Policy applies to the personal data of our Candidates, and other people whom we may contact in order to find out more about our Candidates or whom they indicate is an emergency contact.
We reserve the right to update this Privacy Policy at any time, and we will provide you with a new Privacy Policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.
Our Role
We are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. Data protection legislation requires us to give you the information contained in this Privacy Policy.
Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be:
The Kind of Information we hold about you
Where you contact us directly, the information we collect from you will include anything you provide to us by corresponding with us by phone, email or otherwise.
During the recruitment process, the information we collect may come from our third party service providers and publicly available websites to which you are registered or subscribed.
The information you give us or we collect may include your name, address, phone number, information listed on your CV including employment history and education.
As part of our registration, you will be required to provide additional information to satisfy our own legal requirements as well as those of our clients. Such information would include sensitive personal information such as criminal allegations or convictions, references, passport numbers and any other required Right to Work confirmations.
Purpose of processing and legal basis
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. The legal basis we rely upon to offer these services are:
Consent
We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We may market products or services to you which are related to the recruitment services we provide as long as you do not actively opt-out from these communications.
As we have mentioned, you have the right to withdraw your consent to these activities at any time.
Legitimate interest
Where the Company has relied on a legitimate interest to process your personal data our legitimate interests are as follows:
Candidate Data
How do we safeguard your personal data?
We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having a range of appropriate technical and organisational measures in place. These include measures to deal with any suspected data breach.
Recipients of data/Legal Obligation
The Company may share or process your personal data and/or sensitive personal data, in various ways and for various reasons, with the following recipients:
Statutory/contractual requirement
Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract.
Several elements of the personal data we collect from you are required to enable us to fulfil our contractual duties to you or to others. For example, some Candidates’ National Insurance numbers and right to work in the UK are required by statute or other laws. Other items may simply be needed to ensure that our relationship can run smoothly.
Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship.
The Company may transfer 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.
The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.
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 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 data and sensitive personal data.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer seeking work we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Please be aware that you have the following data protection rights:
Your rights in relation to personal information:
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Alex Stead – Data Controller at alex.stead@henry-blue.co.uk
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Alex Stead – Data Controller at alex.stead@henry-blue.co.uk . Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
We will seek to deal with your request without undue delay, and in any event within 30 days (subject to any extensions to which we are lawfully entitled). Please note we may keep your communications to help us resolve any issues which you raise.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We can use automated decision-making in the following circumstances:
If we make an automated decision based on any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Henry Blue Ltd uses cookies to help us identify and track visitors, their usage of our website, and their website access preferences. Henry Blue Ltd visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Henry Blue’s website, with the drawback that certain features of the website may not function properly without the aid of cookies. For more information about cookies visit www.aboutcookies.org
We sometimes embed photos, videos or tweets from websites such as news articles and LinkedIn. Pages with this embedded content may present cookies from these websites. Similarly, if you use a share button on our website, a cookie may be set by the service you have chosen to share content through. We do not control the dissemination of these cookies. You should check the relevant third party website for more information about these.
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over the other website. Therefore, we cannot be responsible for the protection and privacy of any information you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
If you wish to complain about this Privacy Policy or any of the procedures set out in it, please contact:
Alex Stead – Data Controller – alex.stead@henry-blue.co.uk
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.
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