SourceCo Recruitment Limited’s Privacy Notice
SourceCo Recruitment Limited (“SourceCo”, “we”, “us”) are committed to protecting the privacy of our candidates, clients and users of our website. This notice sets out the basis on which we process any personal data which we collect or is submitted to us.
SourceCo is the ‘Controller’ of the personal data which is provided to us. SourceCo’s registration number is 11586382 and our registered address is Alacrity House, Saxon Business Park, Hanbury Road, Stoke Prior, Worcestershire, England, B60 4AD.
The Company has registered with the ICO and its registration number is ZA542550
- Who are we and what do we do?
- What data do we collect?
- How do we collect your data?
- How will we use your data?
- How do we store your data?
- What is the legal basis for processing your data?
- What are your data protection rights?
- Who do we share your data with?
- How to make a data subject access request?
- Changes to our privacy notice
- How to contact us
- How to contact the appropriate authority
Who are we and what do we do
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Business Regulations 2013. We collect and process personal data and sensitive data from the following types of individuals to allow us to undertake our business:
- Prospective and placed candidates for permanent and contract roles
- Prospective and live client contacts
- Supplier contacts to support our services
- Employees, consultants, temporary workers
What data do we collect?
In order to deliver our recruitment service, we need to process certain personal data. Personal data is information relating to an individual who can be identified including an individual’s name, contact details, employment history, education details, and immigration status (and other relevant information which any individual may decide to share). We only request details which we genuinely require.
Where appropriate, and in accordance with local laws and requirements, we may also collect sensitive personal data which means personal data relating to but not limited to, diversity, political opinions, religious beliefs, security clearance status or details of any criminal convictions.
We collect and use information about our clients, or individuals at their organisation. We ask for details so that we can find candidates to fill their roles, provide Recruitment Process Outsourcing (RPO) services or notify them of relevant content which we have published.
We also store information relating to our previous dealings, including job applications, email and telephone details, job interviews and placements.
We collect a limited amount of data from the users of our website which we use to improve the experience of our website and help us to manage our service provision. This includes how our users use our website, the most popular referrers and website responsiveness. More information regarding this is available from our Cookies Policy.
How do we collect your data?
We obtain candidate information via many methods including but not limited to:
- Registering, or applying for jobs, via our website
- Corresponding with us via phone, email or otherwise
- Visiting our website
- Registering a CV on a job board which matches the skills we are seeking
- Applying for one of our jobs via a job board
- Referring a friend or colleague
- Online profiles
When we obtain information via external sources including but not limited to, LinkedIn, corporate websites and job boards, we will notify you accordingly. We will send you a copy of this privacy notice within a maximum of 30 days of collecting your data. We will state that we hold your personal data, the source it originates from, and for what purpose we intend to retain and process the personal data.
There are two main ways in which we collect client data:
- Directly from the client
- From third parties such as candidates, online job boards, LinkedIn and networking.
How will we use your data?
SourceCo takes everybody’s privacy seriously and will only use any personal information to administer an account and to provide recruitment services.
We believe that if you have posted your CV on a job board or professional networking site, then you understand that we will collect and otherwise use your personal data to provide our recruitment services to you, share your information with prospective employers (with your consent) and review your skills against our live vacancies. During the job offer process, your potential employer may also want to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with the law.
We believe that it is reasonable for us to process personal data so that we are able to provide you with tailored job adverts to assist with your recruitment.
We also use personal data for our internal administrative purposes, including payroll and invoicing where applicable.
How do we store your data?
All of the personal data that we hold will be processed by our employees in the United Kingdom, and accessed by our CRM system, MatchMaker We take all reasonable steps to ensure that all personal data is processed securely and prevent unauthorised access to, and misuse of, your personal data.
Where a password exists to enable access to certain parts of our website, you are responsible for keeping your password confidential. This password should not be shared with anyone.
We are required to keep the data we hold accurate and, where necessary, up to date. We will make an effort to regularly communicate with you to ensure this, however you should inform us if your data changes.
We will delete candidate personal data from our systems if we have not had any meaningful contact with you for seven years (or for such longer period as we believe, in good faith, that the law or relevant regulators require us to preserve the data). After this period, it is likely that your personal data will no longer be relevant for the purposes for which it was collected.
We will consider there to be meaningful contact with you if you submit your updated CV onto our website, apply for jobs with us or we receive an updated CV from a job board. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or engage with any of our marketing communications.
Whilst we will endeavour to permanently erase all personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our archives. This data cannot be readily accessed by our operational systems, processes or employees.
For a list of all data categories and retention periods, please contact firstname.lastname@example.org
What is the legal basis for processing your data?
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract where we are negotiating or have entered into a placement agreement with you or your organisation, or any other contract to provide services to you, or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold your information to fulfil our legal obligations.
We will, in some circumstances, rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. An example of when consent may be the lawful basis for processing includes permission to introduce a candidate to a client.
Who do we share your data with?
We will always obtain express consent before we share any personal information with prospective employers.
Unless requested otherwise, we may also share personal information with associated third parties such as our service providers where we feel this will help us to provide the best possible service and we have the appropriate processing agreement in place.
What are your data protection rights?
SourceCo would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request SourceCo for copies of your personal data. Please see “How to make a data subject access request?” for more information.
The right to rectification – You have the right to request that SourceCo correct any information you believe is inaccurate. You also have the right to request SourceCo to complete the information you believe is incomplete.
The right to erasure – You have the right to request that SourceCo erase your personal data, under certain conditions.The right to restrict processing – You have the right to request that SourceCo restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to SourceCo’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that SourceCo transfer the data that we have collected to another organization, or directly to you, under certain conditions.
How to make a data subject access request?
You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete your information. There is no administration charge for access to your personal data at any time (unless the request is excessive) and the request should be fulfilled within 30 days. To request access to any information, please email email@example.com
Changes to our privacy notice
How to contact us
Questions, comments or requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org
How to contact the appropriate authority
Should you wish to report a complaint or if you feel that SourceCo has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office’s helpline on 0303 123 1113.
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