Privacy Policy 

 

 

Company Name:      Sourcing Pro Recruitment Ltd (‘the Company’)

Company Contact  details:  Data Protection Lead – Royanne Johnson.   info@sourcingprorecruitment.co.uk

Document: Privacy Notice

Topic:  Data protection

Date:  23.11.23

Version:  1

 

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.  

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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 this privacy statement. At all times we will comply with current data  protection laws.  

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Contents 

1. Collection and use of personal data  

a. Purpose of processing and legal basis 

b. Legitimate interest 

c. Statutory/contractual requirement 

d. Recipients of data 

2. Information to be provided when data is not collected directly from the data subject a. Categories of data 

b. Sources of data 

3. Overseas transfers 

4. Data retention 

5. Your rights 

6. Login files 

7. Links to external sites 

8. Sale of the business 

9. Data security 

10. Changes to this privacy statement 

11. Complaints or queries 

1. Collection and use of personal data 

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a. Purpose of processing and legal basis 

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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. This includes  for example, contacting you about job opportunities, assessing your suitability for those opportunities,  updating our databases, putting you forward for job opportunities, arranging payments to you and  developing and managing our services and relationship with you and our clients.  

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In some cases we may be required to use your data for the purpose of investigating, reporting and  detecting crime and also to comply with laws that apply to us. We may also use your information  during the course of internal audits to demonstrate our compliance with certain industry standards. 

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our  work-finding services to you are: 

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• Your consent 

• Where we have a legitimate interest  

• To comply with a legal obligation that we have. 

• To fulfill a contractual obligation that we have with you. 

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b. Legitimate interest 

This is where the Company has a legitimate reason to process your data provided it is reasonable and  does not go against what you would reasonably expect from us. Where the Company has relied on a  legitimate interest to process your personal data our legitimate interests is/are as follows: 

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• Managing our database and keeping work-seeker records up to date;  

• Providing work-finding services to you and our clients; including sending information to  prospective employers where you have demonstrated an interest in doing that particular type of  work. 

• Contacting you to seek your consent where we need it;  

• Giving you information about similar products or services that you have used from us recently; 

 

c. Statutory/contractual requirement.

The Company has certain legal and contractual requirements to collect personal data (e.g. to comply  with the Conduct of Employment Agencies and Employment Businesses Regulations 2003,  immigration and tax legislation, and in some circumstances safeguarding requirements.) Our clients may also require this personal data, and/or we may need your data to enter into a contract with you.  If you do not give us personal data we need to collect we may not be able to continue to provide work finding services to you.  

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d. Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following  recipients: 

• Clients (whom we may introduce or supply you to) 

• Former employers whom we may seek references from 

• Payroll service providers who manage payroll on our behalf or other payment intermediaries  whom we may introduce you to  

• The Recruitment and Employment Confederation (and any other trade body that you are a  member of who may have access to your candidates’ data) 

• Company Accountant – if required 

• IT provider – if required 

• The Disclosure and Barring Service (DBS) 

• APCS – Criminal record checks 

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2. Information to be provided when data collected not from the data subject] Categories of data: The Company has collected the following personal data on you: 

Personal data: 

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• Name and Date of Birth 

• Contact details, including telephone number, email address and postal address. • Experience, training, and qualifications 

• CV 

• Identification documents 

• Eligibility to work in the UK documents including NI number. 

• Teacher reference number 

• Referee details 

Sensitive personal data: 

• Health information including whether you have a disability. 

• Criminal conviction. 

• List 99 – Barred List checks 

Source of the personal data: The Company sourced your personal data/sensitive personal data: • From CV Library jobs board, LinkedIn 

• Teacher training event 

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This information came from a publicly accessible source. 

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3. Overseas Transfers [Optional] 

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. 

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4. Data retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect  it. Different laws may also require us to keep different data for different periods of time. For example,  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. This is currently 3 to 6 years.  

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Where the Company has obtained your consent to process your personal/ 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. 

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5. 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. 

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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 our Data Protection Officer  – Royanne Johnson (info@sourcingprorecruitment.co.uk). Please note that if you withdraw your  consent to further processing that does not affect any processing done prior to the withdrawal of that  consent, or which is done according to another legal basis.  

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There may be circumstances where the Company will still need to process your data for legal or official  reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary  for those specific reasons.  

If you believe that any of your data that the Company processes is incorrect or incomplete, please  contact us using the details above and we will take reasonable steps to check its accuracy and correct  it where necessary.  

You can also contact us using the above details if you want us to restrict the type or amount of data  we process for you, access your personal data or exercise any of the other rights listed above.

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6. Log Files 

We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather  broad demographic information for aggregate use. IP addresses are not linked to personally  identifiable information.  

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7. Links to external websites 

The Company’s website may contain links to other external websites. Please be aware that the  Company is not responsible for the privacy practices of such other sites. When you leave our site we  encourage you to read the privacy statements of each and every website that collects personally  identifiable information. This privacy statement applies solely to information collected by the  Company’s website.  

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8. Sale of business 

If the Company’s business is sold or integrated with another business your details may be disclosed to  our advisers and any prospective purchasers and their advisers and will be passed on to the new  owners of the business. 

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9. Data Security 

The Company takes every precaution to protect our users’ information. Security measures in relation  to personal data processed include; firewalls, limited access and use of passwords.

 

Only employees who need the information to perform a specific job (for example, consultants, our  accounts clerk or a marketing assistant) are granted access to your information.  

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The Company uses all reasonable efforts to safeguard your personal information. However, you should  be aware that the use of email/ the Internet is not entirely secure and for this reason the Company  cannot guarantee the security or integrity of any personal information which is transferred from you  or to you via email/ the Internet. 

If you share a device with others we recommend that you do not select the “remember my details”  function when that option is offered.  

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10.Changes to this privacy statement 

We will update this privacy statement from time to time. We will post any changes on the statement  with revision dates. If we make any material changes, we will notify you.  

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11.Complaints or queries 

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Danielle Holt – Data Protection Officer (info@sourcingprorecruitment.co.uk 

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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.