Who are we?
Cottons Centre, Hays Lane, SE1 2QP
Tel: 020 7557 7667
We provide permanent and temporary recruitment services to clients looking to recruit personnel for their businesses.
What does this Policy cover?
We at Venn Group take your personal data seriously.
·sets out the types of personal data that we collect about you
·explains how and why we collect and use your personal data
·explains how long we keep your personal data for
·explains when and why we will share your personal data, and who with;
·sets out the legal basis we have for using your personal data;
·explains the effect of refusing to provide the personal data requested;
·explains the different rights and choices you have when it comes to your personal data; and
·explains how we may contact you and how you can contact us.
What personal data do we collect about you?
Candidates and Contractors
We collect the information necessary to be able to find available job opportunities, and that is needed to check your eligibility for work. This information may be used at several stages of recruitment, from first introduction, through screening and interviews, to final appointment. The information will normally include your name, where we can contact you (phone, email address etc.), date of birth, work and educational history (CV), proof of identity (residential address, national insurance number, passport etc.), photograph, employer references, and bank details (to ensure that you can be paid). It may sometimes need to include other information such as proof that you are eligible to work in the UK (for example, immigration, nationality and criminal conviction records), contact details for your reference providers, and information from the employer organisation that we work with.
In some circumstances we may also need to collect sensitive data, such as your personal medical information. We only collect and hold this after you have given us your explicit consent to do so.
We collect contact details normally including your names, job titles, telephone numbers and email addresses to enable us to tell you about potential workers we have for you. In our contracts with you we will also normally hold contact details of principal parties to the contract.
We collect your contact details such as your names, job titles, telephone numbers and email addresses to enable us to contact you to contract with you for the services you are providing. We also hold your financial information to enable us to pay you.
Where do we collect personal data about you from?
The following are the different sources we may collect personal data about you from:
·You, directly: As either candidate or client, you would normally offer information to support your search for a new opportunity for employment and/or during later stages of the recruitment process.
·An agent/third party acting on your behalf. e.g. Contractors Limited Company.
·Sources where you have yourself made the data publicly available. We use published sources such as:
·A reference or word of mouth. For example, you may be recommended to us by a friend, a former or present employer or colleague.
Where we collect your information through publicly available sources, where you have yourself already published this information, we may use the (job board) publisher’s own search software to do this. Such search tools use the publisher’s own parameters to express the requirements of a role and then to search the publicly available source to identify candidates who match the selected requirements. The publisher’s search tools only output information on candidates that meet preset search criteria, restricted to: candidates’ name, skills, location, role and pay sought. In registering and publishing their own personal data on public sites, candidates are expressing a reasonable expectation that their information may be collected and further processed by job recruiters for the purposes of identifying and assisting candidates to gain employment.
How do we use your personal data?
We use your personal data to match your skills, experience and education with the requirements expressed by a potential employer. We will initially collect basic information on you such as contact details, job role, experience and eligibility to work, then pass this on to relevant employer clients. If you are chosen by the client and go through to the next stage we will then collect more information from you at the interview (or equivalent) stage and onwards in that manner. We also have legal obligations to share your information in connection with tax collection, crime detection or other reasons defined by legal authorities.
To help you in your job search, we may provide you with job recommendations or other relevant information, and may send you electronic communication as well as contacting you by phone.
We collect contact details to enable us to tell you about potential workers we have for you. Our contracts with you will also normally hold contact details of principal parties to the agreement.
How long do we keep your personal data for?
We keep your information for as long as Data Protection standards recommend:
·for up to 2 years from our last meaningful contact with you
·for 7 years from the end of the tax year to confirm relevant Income Tax, pension and VAT records against payroll
Contractor data: 7 years from the end of each tax year, as required by law governing the retention of payroll and VAT records
In some circumstances we are required by law to retain your data for longer than a 7 year period. These circumstances include legal or contractual aspects of certain specific roles (such as regulator registered Senior Managers in financial firms), or where your experience includes a significant specialist skill set which may remain in demand for a longer period of time.
Client contact details: So that we remain able to provide you with contract and interim employees, your contact details will be retained for the period of 7 years since the last meaningful contact with you.
More detailed information on retention periods for different categories of data is identified in our Data Retention Policy, available on request.
Who do we share your personal data with?
Candidates: We share your personal data with:
·the client who has a position to fill, to help determine whether you are a good fit for the available position.
·external verifiers:Employers require us to check and verify some parts of the information you have provided.To do this we may share your information with background checking authorities such as your referees, qualification providers, occupational health providers, credit checking agencies, Pension Providers or HM Government’s Disclose and Barring Service agency. All of these third parties are UK based.
·any regulatory authority or statutory body following an official request for information or under a legal obligation we have, such as to co-operate with HMRC, Pension Providers, or the Police.
·Third parties that process data on our behalf include: storage service providers, CRM, cloud and other IT system contractors, candidate registration portals, companies undertaking customer satisfaction survey or external consultants, business associates and professional advisers.
What legal basis do we have for using your information?
For prospective candidates, contractors, referees and clients, our processing is necessary for our legitimate interests as a provider of recruitment services. We process the information needed for us to assess candidate suitability for potential roles, to find potential candidates and to contact clients and referees. We carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to and can find out more about the information in these balancing tests by contacting us using the details below.
For candidates: If you are interviewed and submitted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case we always ask for your consent before undertaking such processing.
For clients: We may also rely on our processing being necessary to perform our contract with you, for example in contacting you.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
Candidates: If you do not provide the personal data necessary, or withdraw your consent for the processing of your personal data, we may not be able to match you with available job opportunities.
Do we make automated decisions concerning you?
No, we do not carry out automated profiling.
Do we transfer your data outside the EEA?
No, we do not transfer personal data out of the EEA.
What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country. In the UK this is the Information Commissioner’s Office. Your rights are summarised below.
What does this mean?
1. The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
2. The right of access
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
3. The right to rectification
You are entitled to have your information corrected if it’s inaccurate or incomplete.
4. The right to erasure
This is also known as ‘the right to be forgotten’. You may request the deletion or removal of your information where there’s no compelling reason for us to keep using it. There are exceptions to this right, such as that we must keep records of your taxable pay, to show to HMRC if they ask us for this.
5. The right to restrict processing
You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we need to keep sufficient information for us to be able to identify you as someone who has asked us to respect your wish to remain ‘blocked’ – restricting us from making any further use of your information in future.
6. The right to data portability
You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
7. The right to object to processing
You have the right to object to certain types of processing, such as automated decision-making by a computer (which we do not use) and our including you in direct marketing (that is, if you no longer want to be contacted with potential opportunities).
8. The right to complain
You have the right to make a complaint about the way we handle or process your personal data to the UK data protection regulator.
9. The right to withdraw consent
If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
We will normally act on requests and provide information free of charge.
We may charge a reasonable fee to cover our administrative costs of providing the information for:
·baseless, excessive, or repeated requests, or
·further copies of information already provided.
We may be entitled to refuse to act on certain requests.
Please consider any data access request responsibly before submitting it. We will normally respond within one month from when we receive your request. If for some reason the request is going to take longer to deal with, we’ll contact you to let you know.
How will we contact you?
We may contact you by phone, email or social media. If you prefer a particular contact means over another please just let us know.
How can you contact us?
If you have further questions on the processing of your personal data, are concerned about how we’ve handled your information, or would like to exercise any of the rights mentioned above, contact us by emailing to firstname.lastname@example.org or by surface mail to: