Who are we?
The Data Controller and processor is Peaple Talent Ltd, based at UK House, Unit 3 & 7 Netham View Industrial Park Netham Road Bristol BS5 9PQ. We provide permanent and temporary recruitment services to clients looking to recruit personnel for their businesses. Our payroll service is provided through 3R Finance LTD.
What does this Policy cover?
We at Peaple Talent take your personal data seriously. This policy:
- 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, why and with whom we will share your personal data.
- 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: We collect and use only the information necessary to be able to find the best available opportunities and any further information needed to assess your eligibility through the different stages of recruitment. This information includes personal details such as names, telephone numbers, addresses and personal email addresses, CVs, identification documents, educational records, work history, employment and references and financial information.
We may also collect sensitive personal data about you, related to your health, diversity information or details of any criminal convictions. We only collect sensitive personal data from you, and further process this data, where you have given your explicit consent.
Clients: We collect and use only the information necessary to provide you, or people in your organisation with services such as finding the best available candidates for your opportunities.
Other data subjects: We collect and use only the information necessary to be able to contact you and pay you for the services you provide.
Website Users: We collect and use only the information necessary to improve your experience when using our website. This may include how, when, and how often you visit us.
Where do we collect personal data about you from?
- Directly from you. This is information you provide while searching for a new opportunity and/or during the different recruitment stages, or during our work with you to ensure that our relationship runs efficiently.
- From an agent/third party acting on your behalf. E.g. A Contractors Limited Company.
- Through publicly available sources.
- Job Boards (Jobsite & CW Jobs)
- By reference or word of mouth. You may be recommended by a friend, former employer, former colleague, or present employer.
Where we collect your information through publicly available sources as set out above, we may do this with the aid of software programs such as Sourcebreaker and Broadbean. These programs are given parameters on the requirements of a role and search through publicly available sources to find such candidates. These programs are designed to only output information on candidates that meet the search criteria. The parameters of this program are restricted to only searching for candidate information from public sites where there is a reasonable expectation that such information may be collected and further processed by job recruiters for sourcing candidates for different job roles.
How do we use your personal data?
Candidates: We use your personal data to match your skills and experience with a potential employer. We will initially collect basic information on you such as contact details, job role and experience and then pass this on to the client in search of personnel. If you are chosen by the client and go through to the next stage, we will then be collecting more information from you at the interview (or equivalent) stage and onwards in that manner. We may use your data to send you information that you may find interesting such as suggesting other jobs to you.
Clients: We use your personal data to ensure that we can find the right candidates for the opportunities that you may have or for contractual obligations.
Suppliers: We use your personal data to ensure that we can contact you and for contractual obligations.
Communications: We may use your Personal Information to contact you with newsletters and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
How long do we keep your personal data for?
- If you are a Client or a Supplier, we will retain your personal data to provide you with services or to receive services from you, or to provide you with information about our services that we believe you may be interested in. If you have expressly indicated that you are not interested in our services, then we will delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example because of our obligations to tax authorities or in connection with any anticipated litigation).
- If you are a prospective candidate or a candidate, we will delete your personal data from our systems if we have not had any meaningful contact with you (or where appropriate, the company you are working for or with) for two years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data).
- If you have expressly indicated as a prospective candidate or a candidate that you would rather, we did not retain your personal data then we will delete it from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).
- For those candidates, whose services are provided via a third-party company or other entity, “meaningful contact” with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than two years from that point or, if later, for the period of two years from the point we subsequently have meaningful contact directly with you.
- When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written).
- If you are a Prospective Candidate, we will consider there to be meaningful contact with you when we first contact you in relation to our services. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication.
- The precise length of time will depend on the type of data, our legitimate business needs and other legal or regulatory rules that may require us to retain it for certain minimum periods. For example, we may be required to retain certain data for tax reporting or responding to tax queries. We may also retain it if it might be relevant to any potential litigation. In jurisdictions that allow it, we will generally retain personal data relating to you where necessary to enable us to provide you or a future employer with a reference.
- In determining the appropriate retention period for different types of personal data, we always consider the amount, nature, and sensitivity of the personal data in question, the potential risk of harm from unauthorised use or disclosure of that personal data, the purposes for which we need to process it and whether we can achieve those purposes by other means (besides of course to ensuring that we comply with our legal, regulatory and risk-management obligations, as described above). For the avoidance of doubt, if you are a Temporary Worker, we will also continue to process your personal data as a Candidate through the duration of your Temp Relationship and thereafter. The question of whether and the extent to which we will continue to process your personal data as staff data through the duration of your Temp relationship and thereafter depends on local law requirements
Who do we share your personal data with?
Candidates: We share your personal data with the client who has a position to fill, to determine with the client whether you are a good fit for the available position.
We may also conduct checks on you to verify the information you have provided and where we do this, we share your information with our appointed background checking company.
Unless you specify otherwise, we may share your data with any of our associated third parties – for example, our payroll and pension providers – to provide you with the best possible service.
Clients: We share your data with candidates while providing recruitment services to you, and with third parties as part of our contractual relationship.
Suppliers: We share your data with third parties as part of our contractual relationship.
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 – we need this information to be able to assess suitability for potential roles, to find potential candidates and contact clients and referees, and suppliers.
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.
We will rely on legitimate interest for recruitment related activities where you engage with us by agreeing to share a CV or applying for a job. This means we take your consent as given unless or until you opt-out.
If we collect your personal information due to legitimate interest through publicly available sites, such as LinkedIn and/or job boards, we will inform you of this and give you the option to be erased.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
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?
We do not make any automated decisions concerning you, all screening is done manually.
Do we transfer your data outside the EEA?
No, we do not transfer personal data out of the EEA.
How do we safeguard and store your personal data?
We take the security of your data very seriously and have put in place appropriate measures that are designed to prevent unauthorised access to or misuse of your personal data. We limit access to your personal data to those who have a genuine business need to know it. We have procedures in place to deal with any suspected data security breach.
Your data is stored in:
- Bullhorn Inc
- Sense HQ
- 3R Finance
What rights do you have concerning the data we hold on you?
By law, you have several 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.
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. Therefore, we are providing you with the information in this Policy.
2.The right of access
3.The right to rectification
You are entitled to have your information corrected if it is inaccurate or incomplete.
4.The right to erasure
This is also known as ‘the right to be forgotten’. In simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
In the case that we erase your data, if your CV and information remains publicly available, either through LinkedIn or other Job Boards, there is a high chance we might pick up your details again. So we would recommend removing your details from all publicly available sites.
5.The right to restrict processing
You have the right to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6.The right to data portability
You have the right 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, including processing for direct marketing.
8.The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal data with your national 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 usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
- Alternatively, we may be entitled to refuse to act on the request.
We may also need to verify your identity as part of any request dependent on the nature of the request and your co-operation with this will be required to allow us to share.
Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and 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 any concerns or questions or wish for your data to be removed, you can contact us at firstname.lastname@example.org