1.1 Inter-vention Limited c/o Flexspace Harrogate, Hartwith Way, Harrogate, HG3 2XA (“we” “us” “our”) are committed to protecting and respecting your privacy. For the purposes of data protection legislation, we are the data controller and we will process Your Data in accordance with the General Data Protection Regulation (EU) 2016/679 and national laws which relate to the processing of personal data. Please read the following carefully to understand our views and practices regarding Your Data and how we will treat it.
2. YOUR DATA
3. VISITORS TO OUR WEBSITE
3.1 We may collect and process Your Data in the following circumstances:
3.1.1 when you complete forms on our website (“Site”). This includes information provided at the time of registering to use our Site, subscribing to our services or requesting further services;
3.1.2 whenever you provide Your Data to us when reporting a problem with our Site, making a complaint, making an enquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence;
3.1.3 whenever you disclose Your Data to us, or we collect Your Data from you in any other way, through our Site.
3.2 We may also collect data in the following ways:
3.2.1 We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
3.3 We may use Your Data for our legitimate interests in order to:
3.3.1 provide you with information, or services that you requested from us;
3.3.2 allow you to participate in interactive features of our Site, when you choose to do so;
3.3.3 ensure that content from our Site is presented in the most effective manner for you and for your device;
3.3.4 improve our Site and services;
3.3.5 process and deal with any complaints or enquiries made by you; and
Our site may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of Your Data and we do not accept any responsibility or liability for these policies. When you leave our Site, we encourage you to read the privacy notice/policy of every website you visit.
4.1 We will collect Your Data when you order recruitment services from us. We will use Your Data to process your request for services and comply with our contractual obligations. Subject to your prior consent, this may include sharing personal information in relation to your staff members with our candidates. We will also use Your Data to notify you of any changes to our services and process and deal with any complaints or enquiries made by you.
4.2 We may also advertise your feedback on our website and marketing materials (subject to obtaining your prior consent where necessary).
4.3 We will retain Your Data as long as we require it to provide you with the services ordered from you, and then for a period of 6 years from the date of our last contact with you.
5.1 We will collect Your Data when you provide us with Your Data via our website, over the phone, or by email. Where you register an interest in one of our advertised roles via a third party website or where we are provided with Your Data from a third party organisation such as an outplacement organisation.
5.2 We will use Your Data to provide you with recruitment services and carry out our obligations arising from arrangements entered into between you and us. We will also use Your Data to notify you of any changes to our services and process and deal with any complaints or enquiries made by you. Subject to obtaining your prior consent, we will share Your Data with our clients for their consideration as prospective employers.
5.3 We may also advertise your feedback on our website and marketing materials (subject to obtaining your prior consent where necessary).
5.4 We will retain Your Data as long as we require it to provide you with the services ordered from us or hold an account with us subject to a maximum of three years from the date of our last contact with you.
5.5 Where you are a contractor with us, or we have placed you in a permanent position, we will retain your data as long as we require it to meet our legal and contractual obligations and then for a maximum period of 6 years from the date of our last contact with you.
6.1 We will collect Your Data in order to contact you about goods or services ordered with you, to place further orders and to pay you for the goods and/or services supplied. We will keep Your Data for as long as we require your goods and services subject to a maximum of six years from the date of our last contact with you.
7. IF YOU FAIL TO PROVIDE YOUR DATA
7.1 Where we need to collect Your Data by law, or under the terms of a contract we have with you and you fail to provide the data when requested, we may not be able to perform the contract we have or are trying to enter with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
8. AUTOMATED PROCESSING
8.1 We do not undertake automated decision making with Your Data.
9. LEGAL BASIS FOR PROCESSING YOUR DATA
9.1 We would only use Your Data where the law allows us to. Most commonly, we will use Your Data in the following circumstances:
9.1.1 for performance of a contract we enter into with you;
9.1.2 where we have your consent;
9.1.3 where necessary for compliance with a legal or regulatory obligation we are subject to; and
9.1.4 for our legitimate interests (as disclosed in this policy) where interests and fundamental rights do not override these interests.
10. DISCLOSURE OF YOUR DATA TO THIRD PARTIES
10.1 In addition to the third parties mentioned above for specific data subjects, we may disclose Your Data to third parties for our legitimate interests as follows:
10.1.1 to staff members in order to facilitate the provision of services to you;
10.1.2 to our affiliated entities to support internal administration;
10.1.3 IT software providers that host our website and store data on our behalf;
10.1.4 professional advisers including consultants, lawyers, bankers and insurers who provide us with consultancy, banking, legal, insurance and accounting services; and
10.2 We may disclose Your Data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share Your Data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions of use and other agreements; or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
10.3 We will not sell or distribute Your Data to other organisations without your approval.
11. DATA SECURITY
11.1 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
11.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of Your Data transmitted to our Site; any transmission is at your own risk.
11.3 Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure Your Data against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.
12. CROSS-BORDER DATA TRANSFERS
12.1 Some of our clients may process candidate data outside of the European Economic Area (‘EEA’). We may also need to send personal data relating to our client’s staff to candidates based outside of the EEA. Where this is the case, we will either ensure that adequate levels of protection approved by the European Commission are in place for the security of the transfer of Your Data outside the EEA or we will obtain your express consent prior to the transfer of such data (in relation to client staff, we will ask our clients to obtain staff members consent before such information is shared with us).
13. RIGHTS OF ACCESS, CORRECTION, OBJECTION, DELETION AND RESTRICTING USE OF YOUR DATA
13.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed if Your Data changes.
13.2 Data protection legislation gives you the right to object to the processing of Your Data in certain circumstances or withdraw your consent to the processing of Your Data where this has been provided. You also have the right to access information held about you and for this to be provided in an intelligible form. If you would like a copy of some or all of Your Data, please send an email to email@example.com. In certain circumstances we reserve the right to charge a reasonable fee to comply with your request.
13.3 You can also ask us to undertake the following:
13.3.1 update or amend Your Data if you feel this is inaccurate;
13.3.2 remove Your Data from our database entirely;
13.3.3 send you copies of Your Data in a commonly used format and Your Data transferred to another entity; or
13.3.4 restrict the use of Your Data.
13.4 We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal information that we hold about you. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
13.5 Please send any requests relating to the above to firstname.lastname@example.org specifying your name and the action you would like us to undertake.
14. RIGHT TO WITHDRAW CONSENT
14.1 Where you have provided your consent to the collection, processing and transfer of Your Data, you have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, please contact us at email@example.com.
We may update this policy at any time and any changes will be posted on our Site. Please check periodically for any updates. If we would like to use Your Data for purposes other than those we notified you about at the time of collection, we will notify you and, where required, seek your consent before using Your Data for a new or unrelated purpose. We may process Your Data without your knowledge or consent where required by applicable law or regulations.
16. CONTACT US
If you have any questions, comments or requests regarding this policy or how we use Your Data please contact us at firstname.lastname@example.org. This is in addition to your right to contact the Information Commissioners Office if you are unsatisfied with our response to any issues you raise at https://ico.org.uk/global/contact-us/.
Last updated: May 2018