Bespoke Careers Management (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 we will only use your personal data in accordance with the terms of the following statement.
Collection and use of personal data
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 workfinding services. The legal bases we rely upon to offer these services to you are consent, legitimate interest, legal obligation and contractual obligation, for example:
- Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited by EU or Member State law;
- Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract;
- Processing is necessary for compliance with a legal obligation that the controller is subject to.
Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
- Recruitment activities, to provide you with work-finding services by storing and updating your details on our database, keeping records of our conversations and meetings and information provided to us, so that we can provide targeted services to you;
- Marketing activities, to provide you with market information such as salary guides and to invite you to events;
- For equal opportunities monitoring;
- To help us to establish, exercise of defend legal claims.
The Company will collect and process the following personal data and/or personal data*:
- Date of birth;
- Nationality, citizenship and place of birth;
- CV information such as education and work history;
- Documents provided as proof of right to work such as passport or ID card;
- Contact details including emergency contact details;
- Diversity information;
- Information for payroll processing such as bank details and national insurance (or equivalent);
- Details of your current remuneration and total compensation;
- Extra information that you choose to tell us;
- Extra information that our clients or referees may tell us about you.
* Please note that the above list of personal and sensitive data we may collect is not exhaustive but is only collected within the legal context and purposes listed above.
Recipient(s) of data
The Company will process your personal data and/or sensitive personal data with the following recipients:
- Any of our Bespoke Career Management Group companies;
- Clients of ours who are potential employers with the aim of finding you employment;
- Tax, audit or other authorities, where we believe that the law or other regulation requires it;
- Third party services providers who perform functions on our behalf, including payroll providers, lawyers, auditors, accountants, technical support functions and information technology consultants;
- Organisations for whom the candidate has requested Bespoke Careers to act as a referee;
- If Bespoke Careers Management merges with or is acquired by another organisation, or is in discussions to do so, we may share your personal data with the new or prospective new owners of the organisation.
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. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:
- You will be withdrawn from the contract or permanent placement assigned, or the assignment suspended until the data is provided. An example of such data is a right to work document.
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.
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 autoenrolment 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 such as date of birth, sex/gender, contact details, education and work history, right to work information, copy of your passport or identity card, 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 ranted the Company will cease to process your personal data and sensitive personal data.
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. Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting Sophie Tait, Head of Human Resources at firstname.lastname@example.org.
Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Sophie Tait, Head of Human Resources at 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.