Updated July 2018
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
When does this Privacy Notice apply?
Your privacy is important to us.
Please read it carefully to understand our approach and practices regarding your personal data
Types of data held
We keep several categories of personal data on our prospective candidates in order to carry out effective and efficient processes. We keep this data in recruitment files relating to each vacancy and we also hold the data within our computer systems, for example within Outlook.
As part of our recruitment process, Red Seven may collect a range of information creating Personal Data about you. This includes: (please note that this list is not exhaustive):
personal details such as name, address, email and phone numbers
confirmation of right to work
information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter or summary
reference contact details from former employers
details on your education and employment history etc
if you have a driving licence
If you are a client:
Contact details, name , address, email address, phone number
Vacancy details , job title , job content , salary package
Terms of business , fee charges
If you are a Referee, we will collect, store, and use the following categories of personal information about you:
Personal contact details such as name, title, addresses, telephone numbers, and email addresses;
Your job title and position within your employer; and
Any background information which you may provide to us in the course of your dealings with us.
We do not collect, store or use any “special categories” of sensitive personal information if you are a Referee.
Red Seven may collect this information in a variety of ways. For example,
You may supply this information to us directly:
Through submission of a CV, application or submission of a social media profile such as LinkedIn
Through submission of a passport and/or other ID documentation
Information which is collected by us during interviews or other forms of assessments
What if we obtain your personal data from a third party?
Part of our business activity involves researching information relating to individuals for the purposes of filling job roles. This may include obtaining personal data from online sources, for example we may obtain information from social media sites such as LinkedIn and job boards, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal information about you from hiring organisations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged.
How do we use this information?
We may use your Data for the purposes of reviewing your application and throughout the entire recruitment process. Below you will find an overview of the purposes for which we may process your Data during the recruitment process:
Assess your suitability for employment for the role for which you are applying.
Perform analysis of our applicant pool to better understand who is applying to positions at Red Seven and how to attract top talent
To notify you of new opportunities that may be of interest to you. If you do not want to receive these notifications, please contact us at: firstname.lastname@example.org
Perform any legally-required reporting and respond to legal processes.
In addition, or if you are a client or other third party, we may use information held about you in the following ways:
To carry out our obligations arising from any contracts entered into between you and us
To notify you about changes to any of our services
To provide you with information or services that you expressly request from any of us or which any of us feels may interest you, where you have consented to be contacted for such purposes
To meet any of our obligations under any applicable laws or regulations
To carry out any obligations or provide you with any other services, functionality or content which you specifically agree to
To help us establish, exercise or defend legal claims
We may periodically contact you by telephone, email or other digital means for marketing purposes relating to our services, our website, and/or to research opinion on proposed business developments. We will require your consent if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
You may change your marketing preferences at any time by contacting us at: email@example.com
Where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing related services, we will take your consent as given unless or until you opt out. This is referred to as soft opt-in consent and is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position.
Opt-Out – you are entitled to opt-out from receipt of marketing communication at any time and free of charge by sending an email to: firstname.lastname@example.org
Disclosure of your information
We will never share your Personal Data except in the limited circumstances described here:
Red Seven Associates: Your Personal Data may be shared with certain Associates. Access to Personal Data within Red Seven will be limited to those who have a need to know the information, for the purposes described in this Policy, and may include the HR team, your interviewers, the relevant manager(s) of the respective job offer and other selected personnel within Red Seven.
Service Providers: Like many businesses, we may outsource certain Personal Data processing activities to trusted third party service providers to perform functions and provide services to us, such as IT consultants and companies providing support to or with our business technology systems, or to companies who carry out reference or background checking on our behalf.
Public and Governmental Authorities. When required by law, or as necessary to protect our rights, we may share your Personal Data to entities that regulate or have authority over Red Seven or our Associates.
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If Red Seven or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
When do we transfer your data outside of the EEA?
As part of the services offered to you, the Personal Data you provide to us may be transferred to or accessed outside of the UK e.g. if you apply for a role outside of the UK. As a result, your Personal Data may be processed outside the country where you live if this is necessary for the fulfilment of the purposes described in this Policy. If you are applying for a role in the UK, your Personal Data will not be transferred outside of the EEA unless the role itself has a global scope.
These countries may not have similar data protection laws to the EEA. If we transfer your information outside of the EEA in this way, we will take the appropriate steps to ensure that your privacy rights continue to be protected.
We will only hold your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of complying with applicable legal or reporting requirements (for example, our obligations to the tax authorities or under immigration and nationality laws), our contractual obligations or our legitimate interests as a controller.
Some categories of personal data we hold will need to be retained for longer than others. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purpose for which they are processed, the applicable legal requirements and our contractual obligations. Other personal data will be held for no longer than is necessary to protect our legitimate interest as a controller.
In some circumstances we may anonymise personal data so that it can no longer be associated to you, in which case we may use such information without further notice to you.
What are your responsibilities?
We would like to remind you that it is your responsibility to ensure, to the best of your knowledge, that the Data you provide us with are accurate, complete, and up-to-date. Furthermore, if you choose to share Personal Data of other people with us, it is your responsibility to collect such Data in compliance with local legal requirements. For instance, you should inform such other people, whose Personal Data you provide to us, about the content of this Policy and obtain their consent (provided they are legally competent to give consent) for the use of that Personal Data by us as set out in this Policy (including transfer and disclosure).
If you would like to review, change, restrict, or delete the Personal Data you have supplied to us (to the extent Red Seven is not otherwise permitted or required to keep such Data), if you wish to object to certain data processing operations (as permitted by applicable law), or if you would like to receive a copy of your Data (in a common machine readable format, to the extent such is required by applicable law), then you can contact: email@example.com
We will do our best to address your request in time and free of charge, except where it would require a disproportionate effort. In certain cases, we may ask you to verify your identity before we can act on your request.
If you are unhappy with any aspect of the manner in which we have processed your personal data or dealt with your decision to exercise any of the rights set out in this section, you have the right to complain to the Information Commissioners Office in the United Kingdom.
The ICO can be contacted through this link: https://ico.org.uk/.
If, at any time, you want to exercise any of these rights please email us at: firstname.lastname@example.org