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Privacy Policy



Company Name:                       Griffin People Ltd  (‘the Company’)



Company Contact details:                     Alexis Sermbezis
                                                               Tel: +44 (0)1435 873921
                                                Email: adminadmin@griffinpeople.comgriffinpeople.com



Document                                                 Privacy Notice



Topic:                                                       Data protection



Date:                                                        18th May 2018



Version:                                                             2.0




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 job boards. 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.

1.Collection and use of personal data
  a.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.

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.

The legal bases we rely upon to offer these services to you are:

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
Your consent
b. Categories of data

The Company has, or will collect, the following personal data on you, including but not limited to:

Work-seekers

Personal data:
CV
Full Name
Gender
Date of birth
Nationality
Contact details, including telephone number, email address and postal address
Experience, training and qualifications
Current salary and required salary
Current Notice period
Sensitive personal data:

Criminal conviction
Additional data we may require should you secure a permanent or consultancy position:

Passport
Proof of address
National Insurance number
Limited Company name, ownership details, and Incorporation Certificate
VAT registration certificate
Company Insurance certificates
Reference details
Clients

Your job title
Your business contact information including your business email address
Your organisation
Job descriptions
Company benefits
Company policies and procedures
Visitors to our website

We do not use Cookies
If you contact us through our website to submit an application, submit your CV, submit a job description, recommend a candidate or client, or ask a question we will ask you to agree that you accept the terms of this Privacy Notice.
c. 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:

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.
d. Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following recipients:
Our clients
Our work-seekers
HMRC
Background screening partners
e. Statutory/contractual requirement

Your personal data may be 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. If you are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:

As a recruitment business, we will be unable to provide work-finding services to you.
2.Overseas Transfers
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.

3.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.

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.

Where the Company has obtained your consent to process your personal data and sensitive personal data, we will do so in line with our retention policy (a copy of which is attached in Annex B below). 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.

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 data and sensitive personal data you have the right to withdraw that consent at any time by contacting
Alexis Sermbezis on Alexis Sermbezisgriffinpeople.com or 01435 873921

There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting 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.

5.Source of the personal data
If not sent to us directly, The Company sourced your personal data/sensitive personal data by the following means:

Job boards including: Jobserve.com, Jobsite.co.uk, CWJobs.co.uk
Recommendation
Social Media and Networking sites
This information came from a publicly accessible source.


6.Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact:
Alexis Sermbezis on Alexis Sermbezisgriffinpeople.com or 01435 873921.
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.

Annex A

a) The lawfulness of processing conditions for personal data are:


1.Consent of the individual for one or more specific purposes.
2.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.
3.Processing is necessary for compliance with a legal obligation that the controller is subject to.
4.Processing is necessary to protect the vital interests of the individual or another person.
5.Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
6.Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data, in particular where the individual is a child.

b) The lawfulness of processing conditions for sensitive personal data are:

1.Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited by EU or Member State law.
2.Processing is necessary for carrying out data controller’s obligations under employment, social security or social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental rights and interests of the individual.
3.Processing is necessary to protect the vital interests of the individual or another individual where the individual is physically or legally incapable of giving consent.
4.In the course of its legitimate activities, p rocessing is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the consent of the individual.
5.Processing relates to personal data which are manifestly made public by the individual.
6.Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
7.Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law which shall be proportionate to the aim pursued, respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the individual.
8.Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional and subject to the necessary conditions and safeguards.
9.Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy.
10.Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.
Annex B




Company Name:                       Griffin People Ltd  (‘the Company’)



Company Contact details:                    Alexis Sermbezis
                                                               Tel: +44 (0)1435 873921
                                                 Email: adminadmin@griffinpeople.comgriffinpeople.com



Document                                              Data Retention Policy



Topic:                                                       Data protection



Date:                                                       20th May 2018



Version:                                                             1.0




All organisations that process personal data are required to comply with data protection legislation. This includes in particular the Data Protection Act 1998 (or its successor) and the EU General Data Protection Regulation (together the ‘Data Protection Laws’). The Data Protection Laws give individuals (known as ‘data subjects’) certain rights over their personal data whilst imposing certain obligations on the organisations that process their data. As a recruitment business the Company collects and processes both personal data and sensitive personal data. It is required to do so to comply with other legislation. It is also required to keep this data for different periods depending on the nature of the data. This policy sets out how long the Company will keep personal date and sensitive personal data for.




Document type                                  Data retention period



Work-seeker records including        3 years from the last date of
CV, ID checks, terms of                    providing work-finding
engagement (also see below),           services as an Employment
details of assignments, opt-out         Agency or Employment
notices and interview notes.              Business.






Hirer records including client details,
terms of business (also see below),
and assignment/vacancy details.





Terms of engagement with                  6 years from the last date
consultants, temporary workers         of providing work-finding
and terms of business with clients      services as an Employment
(and all other relevant                         Agency or Employment
documentation relating to                   Business, in order to deal
a placed candidate).                             with any civil action
                                                               in the form of
                                                               a contractual claim
                                                               (Limitation Act 1980).



Records held relating
to right to work in
the UK References



References

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