GDPR Transparency Notice

Helen Crawshaw Search Ltd (we) company number 8234384, Registered Office Address: 13 Robert Moffat, High Legh, Knutsford WA16 6PS.

1 What is the purpose of this document?

This transparency notice describes how we collect and use personal information about you during and after your relationship with us.

1.1 We are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you, and for explaining this clearly to you.

1.2 This notice applies to all candidates and to clients, suppliers and service providers to our business.

2 What personal information are we collecting?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are special categories of more sensitive personal data which require a higher level of protection (see section 3).

2.1 For candidates, we will collect, store and use the following categories of personal information about you at the registration stage:

2.1.1 your name, title, addresses, telephone numbers, personal email addresses and password;

2.1.2 your current position and notice period;

2.1.3 salary information (current and desired);

2.1.4 your references and other information included in a CV or cover letter or as part of the application process (including detailing any companies you do not want us to approach);

2.1.5 details of the type of roles you are interested in, including location and relocation information;

2.1.6 your right to work in the UK;

2.1.7 whether you hold a full UK driving license.

2.2 For candidates, we may collect, store and use the following categories of personal information about you at a later stage in the placement process (such as at interview stage, or if given a placement):

2.2.1 your date and place of birth

2.2.2 work history and employment records;

2.2.3 your right to work documents (for example a passport number or Immigration Status Document as set out in the Home Office's right to work checklist, which can be found here: https://www.gov.uk/government/publications/right-to-work-checklist);

2.2.4 a copy of your passport;

2.2.5 a copy of your driving licence and any driving penalties issued against it;

2.3 For clients, suppliers and service providers we will collect, store and use the following categories of personal information:

2.3.1 your name, title and business contact information including addresses, telephone numbers and email addresses; and

2.3.2 we will perform due diligence in the form of credit checks on companies, including checks on the directors, shareholders and verification of the company registration number.

3 Particularly sensitive personal information?

We will also collect the following special categories of particularly sensitive personal information at the registration stage:

(a) information about your health, including any medical condition or disability;

(b) your nationality including whether you have dual nationality; and

(c) information about criminal convictions and offences.

3.1 We will use your particularly sensitive personal information in the following ways:

3.1.1 We use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work and make any reasonable adjustments for the purpose of attending interviews.

3.1.2 We collect and use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

3.1.3 We use information about any spent or unspent criminal convictions and offences to assess your suitability for certain positions. Please note that this may affect our decision to put you forward for a position with a client (employer).

4 How are we collecting your personal information?

4.1 We will collect personal information from you directly when you sign up to use our services by entering information onto our website.

4.2 We will collect information throughout the application and recruitment process, either directly from you or from other employment agencies, head-hunters, job boards or referrals.

4.3 We will sometimes collect additional information from third parties including former employers.

4.4 We verify the information you provide to us on the registration form and in your CV and/or cover letter. To do this, we will collect information from publicly available sources including social media sites including LinkedIn, Facebook and Twitter.

5 For what purpose will we use your personal information?

5.1 We will use all of the categories of information at section 2 above primarily to perform our recruitment contract, or to take steps prior to entering into this contract, with you. To do this, we will process your personal information in the following situations:

5.1.1 to provide our services to you. Our services consist of locating work for persons registered on our database of candidates and introducing such candidates to our clients (employers) with a view to engagement by a client;

5.1.2 to contact you to provide support in relation to your work;

5.1.3 to contact you about jobs that we think you might be interested in; and

5.1.4 to manage our relationship with you.

5.1 We will also use your personal information to:

5.1.1 check you are legally entitled to work in the UK;

5.1.2 ascertain your fitness to work;

5.1.3 monitor your use of our information and communication systems to ensure compliance with our IT policies;

5.1.4 ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution; and

6 What are the legal bases for us to use your personal information?

6.1 We wil

l only use your personal information when the law allows us to do so. Most commonly, we will use your personal information in the following circumstances: 6.1.1 where we need to perform the contract we have entered into with you;

6.1.2 where we need to comply with a legal obligation; and

6.1.3 where it is necessary for our legitimate interests (or those of a third party) to ensure the smooth running of our business as a recruitment agency. We are allowed to do this as long as our activities do not disproportionately intrude your privacy.

6.2 We will also use your personal information in the following situations, which are likely to be rare:

6.2.1 where we need to protect your interests or someone else's interests;

6.2.2 or otherwise with your consent.

6.3 Some of the above grounds for processing your personal information will overlap, and there may be several grounds which justify our use of this information.

7 Who are we going to share your personal information with and what will they do with it?

7.1 Unless this would be unfair to you, we have a legitimate interest in the smooth running of our business and in promoting and growing it. To do this, we will share your personal data with:

7.1.1 our clients as prospective employers;

7.1.2 any other potential employers that you have agreed we may contact on your behalf; and

7.2 If you object to our sharing or continuing to use your personal data with any specific recruiter or potential employer please contact us at helen@helencrawshaw.com

8 If you fail to provide personal information

8.1 In order for us to provide our service, you are contractually required to provide the personal information set out in 2.1 and 2.2 of this notice. If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as introducing you to our clients or providing employment guidance).

Your duty to inform us of changes

8.2 It is important that the personal information we hold about you is accurate and current. Please keep us informed if any of your personal information changes during your working relationship with us by email to helen@helencrawshaw.com

9 Change of purpose

9.1 We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

9.2 Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

10 Automated Decision-Making

10.1 You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have first notified you.

11 Where will we store your personal information?

11.1 Any personal information that you submit to us will be held on secure servers, based within the European Economic Area (EEA).

11.2 We may transfer information about you outside the EEA if it is necessary for a specific job opportunity and only with your consent.

12 Data Security

12.1 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

13 How long will we use your personal information for?

13.1 We will keep your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

13.2 For candidates and contacts, we will keep your personal information in our database for 10 years from our last communication with you, unless you tell us otherwise, to consider you for future opportunities.

14 Your rights in relation to our processing of your personal information

14.1 You have the right to be informed about what we are doing with your personal information. This transparency notice sets out how we use it. If we change what we are doing we will provide you with an updated version of this notice.

14.2 You have the right to object to the processing of your personal information.

14.3 You have the right to request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

14.4 If the personal information we hold about you is incorrect or out of date you can ask us to correct it.

14.5 You have the right to ask us to delete the information that we hold about you where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you ask us to delete your personal information we will not be able to provide our services to you.

14.6 You have the right to ask us to restrict how we use your personal information for a period of time if you claim that it is inaccurate, and we want to verify the position, or if our processing is unlawful but you do not want us to erase your personal information, or for some other limited circumstances. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. If you ask us to restrict our use of your personal information, we may not be able to provide you with our services.

14.7 You can also ask us to send another organisation information that you have provided to us in a format that can be read by computer.

14.8 Where we rely on consent to process your personal information, you have the right to withdraw that consent.

14.9 If you want to exercise any of your rights set out at 14.1 to 14.8, please contact helen@helencrawshaw.

14.10 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).

15 Changes to this transparency notice

15.1 We reserve the right to update this transparency notice at any time, and we will provide you with a new transparency notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

15.2 If you have any questions about this transparency notice, please contact helen@helencrawshaw.com.

16 Complaints Procedure

16.1 If you consider that we have not acted properly when using your personal information you can contact the Information Commissioner's Office: ico.org.uk.