Privacy Notice

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

Contents

1. Collection and use of personal data
   1. Purpose of processing and legal basis
   2. Legitimate interest
   3. Statutory/contractual requirement
   4. Recipients of data
2. Information to be provided when data is not collected directly from the data subject
   1. Categories of data
   2. Sources of data
3. Overseas transfers
4. Data retention
5. Your rights
6. Cookies
7. Login files
8. Links to external sites
9. Sale of the business
10. Data security
11. Changes to this privacy statement
12. Complaints or queries

1. Collection and use of personal data
   1. 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. 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.

      We may also send you marketing information and news via email/ text.  You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.

      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:

      • Your consent
      • Where we have a legitimate interest
      • To comply with a legal obligation that we have
      • To fulfil a contractual obligation that we have with you
   2. 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:

      • Managing our database and keeping work-seeker records up to date;
      • Providing work-finding services to you and our clients;
      • 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;
   3. 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.

   4. 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)
      • Candidates’ former or prospective new employers that you obtain or provide references to
      • Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to
      • Any umbrella companies that you pass candidate data to
      • Any other  third parties who carry out audits to ensure that our business is run correctly
      • Other recruitment agencies in the supply chain (e.g. master/neutral vendors and second tier suppliers);
      • Our insurers
      • Our legal advisers
      • Social networks
      • Our IT and CRM providers
      • Government,  law enforcement agencies and other regulators e.g the Police, Home Office and HMRC
      • Any other organisations you ask us to share your data with.
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:

   • Name, address, mobile no., email
   • National insurance no.
   • Nationality (through right to work check)
   • Date of Birth
   • Photograph
   • Marital status
   • Employment history
   • Education details
   • Copy of driving licence and / or passport / identity card
   • Details about your current remuneration, pensions and benefits arrangements
   • Reference details and references
   • Any extra information you choose to tell us

   Source of the personal data: The Company sourced your personal data/sensitive personal data:

   • Jobs boards
   • LinkedIn or other social media
   • A former employer
   • A referee whose details you previously provided to us
   • Referrals
   • Software provides who we use to support our services
   • Cookies listed in section 5

   This information came/did not come from a publicly accessible source.

   We endeavour not to hold sensitive personal data but if required we will discuss this with you individually and request your consent.

3. Overseas Transfers

   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.

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.

   Where the Company has obtained your consent to process your personal and sensitive 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 and sensitive personal data.

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.

   Where you have consented to the Company processing your personal and sensitive personal data you have the right to withdraw that consent at any time by contacting Robert Ferrari E: robert@ashbrittle.com or Richard Bell E: richard@ashbrittle.com or telephone 01727 854 054.

   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.

   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.

6. Cookies

   We may obtain data about you from cookies.  These are are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.

   The table below explains the cookies we use and why.

   We use cookies and similar tools across our websites to improve their performance and enhance your user experience. This policy explains how we do that.

   What are cookies?

   Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page. The cookie will help the website, or another website, to recognise your device the next time you visit. Web beacons or other similar files can also do the same thing. We use the term “cookies” in this policy to refer to all files that collect information in this way.

   There are many functions cookies serve. For example, they can help us to remember your username and preferences, analyse how well our website is performing, or even allow us to recommend content we believe will be most relevant to you.
   
   Certain cookies contain personal information – for example, if you click to “remember me” when logging in, a cookie will store your username. Most cookies won’t collect information that identifies you, and will instead collect more general information such as how users arrive at and use our websites, or a user’s general location.

   What sort of cookies do you use?

   Generally, our cookies perform up to four different functions:
   
   1. Essential cookies
   Some cookies are essential for the operation of our website. For example, some cookies allow us to identify account holders and ensure they can access the account holder only pages. If an account holder opts to disable these cookies, the user will not be able to access all of the content that a subscription entitles them to. This is why these cookies are always switched on as they are classed as essential for this website to function.

   2. Performance Cookies
   We utilise other cookies to analyse how our visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customising our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or site services that we think will be of interest to you based on your usage of the website.

   3. Functionality Cookies
   We use functionality cookies to allow us to remember your preferences. For example, cookies save you the trouble of typing in your username every time you access the site, and recall your customisation preferences, such as which regional edition of the website you want to see when you log in.
   We also use functionality cookies to provide you with enhanced services such as allowing you to watch a video online or comment on a blog.
   
   Does anyone else use cookies on your website?
   We also use or allow third parties to serve cookies that fall into the four categories above. For example, like many companies, we may use Google Analytics to help us monitor our website traffic. We may also use third party cookies to help us with market research, revenue tracking, improving site functionality and monitoring compliance with our terms and conditions and copyright policy.

   Can a website user block cookies?
   As we’ve explained above, cookies help you to get the most out of our websites.
   The first time you accessed our website after 22 May 2012, you should have seen an overlay which explained cookies and give you the option to allow all non essential cookies.
   Please remember that if you do choose to disable cookies, you may find that certain sections of our website do not work properly

   Do we track whether users open our emails?
   Our emails may contain a campaign-unique item or link to tell us whether our emails are opened and verify any clicks through to links or advertisements within the email. We may use this information for purposes including determining which of our emails are more interesting to users, to query whether users who do not open our emails wish to continue receiving them and to inform our advertisers in aggregate how many users have clicked on their advertisements. The item or link will be deleted when you delete the email.

   More Information
   More detail on how businesses use cookies is available at www.allaboutcookies.org.

   Cookies set by your social networks

   Google+

   Cookie name	Expires after	Description of cookie
   NID	6 months	A unique identifier used by Google applications to store user preference information.
   HSID	10 years	A unique identifier used by Google applications to store user preference information.
   SSID	10 years	A unique identifier used by Google applications to store user preference information.
   APISID	10 years	A unique identifier used by Google applications to store user preference information.
   SAPISID	10 years	A unique identifier used by Google applications to store user preference information.
   SID	10 years	A unique identifier used by Google applications to store user preference information.
   BEAT	1 day	A persistent cookie that is used to track Google+ (+1) status
   ULS	End of session	A session cookie used to track Google+ (+1) status
   _utma	12 months	This keeps track of the number of times a visitor has been to Google+, when their first visit was, and when their last visit occurred
   _utmb	30 minutes	A timestamp of the exact moment in time when a visitor enters the site
   _utmc	End of session	A timestamp of the exact moment in time when a visitor leaves the site - having waited 30 minutes for another pageview to happen, and if it doesn’t, it expires
   _utmz	6 months	This keeps track of where the visitor came from, what search engine was used, what link was clicked on, what keywords used, and where in the world Google+ was accessed from

   Twitter

   Cookie name	Expires after	Description of cookie
   k	1 week	Twitter image server cookie
   guest_id	24 months	Identifies whether the visitor is a user or guest of Twitter
   original_referer	.	This cookie is used to supply the feed on this site.
   _utma	12 months	This keeps track of the number of times a visitor has been to Twitter, when their first visit was, and when their last visit occurred
   _utmb	30 minutes	A timestamp of the exact moment in time when a visitor enters the site
   _utmc	End of session	A timestamp of the exact moment in time when a visitor leaves the site - having waited 30 minutes for another pageview to happen, and if it doesn’t, it expires
   _utmz	6 months	This keeps track of where the visitor came from, what search engine was used, what link was clicked on, what keywords used, and where in the world Twitter was accessed from
   _utmv	2 years	Used for user-defined reports in Google Analytics classifying the visitor
   _twitter sess	End of session	Defines a unique ID associated with the current user linked to Twitter
   auth_token	End of session	On login
   auh_token_session	End of session	On login
   secure_session	End of session	On login
   twll	10 years	On login
   lang	End of session	On login
   pid	24 months	Used by Twitter (from the share buttons that are embedded in some of our pages)

   Facebook

   Cookie name	Expires after	Description of cookie
   datr	24 months	This identifies the web browser being used to connect to Facebook independent of the logged in visitor. This cookie plays a key role in Facebook’s security and site integrity features
   reg_fb_gate	End of session	This contains the first Facebook page visited
   reg_fb_ref	End of session	This contains the last Facebook page visited
   wd	End of session	This identifies the browser window dimensions
   lsd	End of session	This contains a random value that is set when a Facebook user logs out in order to prevent cross-site request forgery attacks
   c_user	Set by visitor	This contains the user ID of the currently logged in visitor. The lifetime of this cookie is dependent on the status of the "keep me logged in" checkbox. If the checkbox is set, the cookie expires after 30 days of inactivity, otherwise the cookie is a session cookie and will therefore be cleared when the browser exits
   csm	End of session	This cookie is used to integrate the user's Facebook's Like status with the London 2012 site
   lu	2 years	This is used to manage how the login page is presented to the visitor. The lifetime is the same as c_user
   s	End of session
   locale	1 week	This contains the display locale of the last logged in visitor on this browser. This is set after the visitor logs out
   sct	Set by visitor	This contains a timestamp representing the time at which the visitor logged in. This cookie is used to distinguish between multiple sessions created at different times. The lifetime is the same as c_user
   xs	Set by visitor	This contains the session number, a session secret and an optional "secure" flag (if visitor has enabled secure browsing feature). The lifetime is the same as c_user

   Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, please refer to our Cookie policy. Please note that in a few cases some of our website features may not function if you remove cookies from your browser.

7. 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.

8. Links to external websites

   The Company’s website may contains 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. 

9. 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.

10. Data Security

The Company takes every precaution to protect our users’ information. e.g. firewalls, limited access, use of passwords.

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

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.

If you have any questions about the security at our website, you can email Robert Ferrari E: robert@ashbrittle.com or Richard Bell E: richard@ashbrittle.com

1. 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 on our website

2. Complaints or queries

   If you wish to complain about this privacy notice or any of the procedures set out in it please contact:
   Robert Ferrari or Richard Bell

   Suite S1, Unit 1, The Verulam Estate, 224 London Road, St Albans, Hertfordshire, AL1 1JB
   Tel: 01727 854 054

   Mail: robert@ashbrittle.com or richard@ashbrittle.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.