Effra Recruitment Solutions Ltd (“Effra Recruitment”) are committed to protecting the privacy of our candidates, clients and users of our website. 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 jobs board. Effra Recruitment must have a legal basis for processing your personal data. we will only use your personal data in accordance with the terms of the following statement. Except as set out herein and where required or permitted by law or a court of competent jurisdiction, we will not reveal any personal data about you to any third party.
Your new rights under the General Data Protection Regulation (GDPR) are set out in this notice GDPR becomes law on 25th May 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Who controls your personal data?
- Effra recruitment Solutions Limited (Effra recruitment) a company registered in the UK: Company Number 08145949
- Address: PO Box 67083 London SW2 9JT
- The Data protection representative is the Legal Director
- You can contact them at email@example.com
- You can call them on 020 3302 5771
- Effra recruitment UK Limited is registered with the Information Commissioner’s Office Certificate Number Z3527033
What is personal data?
Personal data is data that can identify you as a living individual. There is general personal data such as name, address, National Insurance number and online identifiers/location data. There is also sensitive personal data which includes information on physical and mental health, sexual orientation, race or ethnic origin, religious beliefs, trade union membership and criminal records. Sensitive personal data must be protected to a higher level.
Who we are, what we do and how we get your data
Effra recruitment is a recruitment agency and recruitment business as defined in the Employment Agencies Act 1973 (our business). We also provide training and consultancy services from time to time. We collect the personal data from the following types of people to allow us to undertake our business;
- Prospective and placed candidates for permanent or temporary roles;
- Prospective and live client contacts (including referee contacts provided by candidates);
- Supplier contacts to support our services;
- Employees, consultants, temporary workers and contractors;
You may have applied directly to us or we may have found your details from a jobs board or social networking site. We are able to process your data if we have a legal basis for doing so. Effra Recruitment collects the data we need to process to take steps at your request prior to entering into a contract with you. We may also need to process your data to enter into a contract with you.
In some cases, we need to process data to ensure that we are complying with legal obligations.
For example, it is mandatory to check a successful applicant’s eligibility to work in the UK before employment starts.
- Effra Recruitment have a legitimate interest in processing your personal data.
- We collect information about you to carry out our core business and ancillary activities.
The data we collect and how we use it
The personal data we collect or receive includes the following as applicable:
- Email and other contact details
- Date of birth
- Job history (including information relating to placements through us)
- Educational history, qualifications & skills
- Visa and other right to work or identity information
- Bank details
- National insurance and tax (payroll) information
- Next of kin and family details
- Contact details of referees
- Personal information relating to hobbies, interests and pastimes
- Information contained in references and pre-employment checks from third parties
- Other sensitive personal information such as health records (see ‘Sensitive Personal Data’ section below)
- Your marketing preferences
We may obtain your personal data from the following sources
(please note that this list is not exhaustive):
- You (e.g. a Curriculum Vitae, application or registration form)
- A client
- Other candidates
- Online jobsites
- Marketing databases
- The public domain
- Social Media such as LinkedIn
- At interview
- Conversations on the telephone or video conferencing (which may be recorded)
- Notes following a conversation or meeting
- Our websites and software applications
Where you are a Candidate and we have obtained your personal data from a third party such as an online job board, it is our policy to advise you of the source when we first communicate with you. All information will be treated as above but you will have to inform the third party if you wish for your data to be removed.
How Effra Recruitment uses your personal data:
The processing of your personal information may include:
- Collecting and storing your personal data, whether in manual or electronic files
- Notifying you of potential roles or opportunities
- Assessing and reviewing your suitability for job roles
- Introducing and/or supplying you to actual or potential Clients
- Engaging you for a role with us or with our Clients, including any related administration e.g. timesheets and payroll
- Collating market or sector specific information and providing the same to our Clients
- Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment Services
- Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers
- To market our Recruitment Services
- Retaining a record of our dealings
- Establishing quality, training and compliance with our obligations and best practice for the purposes of backing up information on our computer systems
Effra Recruitments Solutions Ltd legal justification for processing your data:
Effra Recruitment has legitimate business interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.
1. Entering into and performing a contract with you:
In order to provide our Recruitment Services, we may enter into a contract with you and/or a third party. In order to enter into a contract, we will need certain information, for example your name and address. A contract will also contain obligations on both your part and our part and we shall process your data as is necessary for the purpose of those in order to process payroll on your behalf.
2. Compliance with legal obligations (regulatory and statutory obligations):
We must comply with a number of statutory provisions when providing our Recruitment Services, which necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003,
Other statutory obligations that must be complied with including payroll, tax, social security, HMRC reporting requirements, and any other law or regulation.
3. Our legitimate interests (carrying on the commercial activity of the provision of Recruitment Services):
In providing our Recruitment Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include:
Retaining records of our dealings and transactions and where applicable, use such records for the purposes of
- establishing compliance with contractual obligations with Clients or suppliers
- addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
- protecting our reputation
- maintaining a backup of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
- evaluating quality and compliance including compliance with this Privacy Notice
- determining staff training and system requirements
This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes.
4. Consent to our processing of your data:
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 the Legal Director via email firstname.lastname@example.org
You may withdraw your consent to our processing of your personal information for at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legal or contractual obligation to do so
Sensitive Personal Data (SPD)
Sensitive personal data is information which is intensely personal
Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.
Effra Recruitment will confirm that you have explicitly consented to the processing of SPD
Effra recruitment records Sensitive Personal Data for statistical use for example to Identify that we are recruiting from diverse cultural backgrounds and to help us implement/ review our equal opportunities policy
Effra Recruitment solutions may also collect SPD for following reasons:
- For the purpose of our assessment of your suitability for job roles or working capacity
- Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law
- To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims
Who we share personal data with:
We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information include:
- Individuals, hirers and other third parties, necessary for the provision of our Recruitment Services
- Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
- Parties who process data on our behalf include:
- IT support
- storage service providers including cloud
- background screening providers
- Legal and professional advisers
We may use software to review the personal data of individuals recorded on our database, or who have applied for specific roles. The software may determine suitability for a specific role via look up questions and may identify and select individual personal information according to the stored characteristics. For example, the software may enable us to quickly identify individuals from our database who have specific skills, for a role
Transfer of data to other jurisdictions
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to Effra Recruitment during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
Effra Recruitment will need data perform our Recruitment Services. If you do not wish to provide us with information, please notify us. However, please be aware that as a result we may be unable to provide you, or the party you represent, with a Recruitment Service,
How does Effra Recruitment protect data?
We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
Effra recruitment will retain your personal data only for as long as is necessary. Different laws 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.
In most circumstances your data will not be retained for more than 6 years from the last point at which we provided any services or otherwise engaged with you and it is our policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests.
Where the Company has obtained your consent to process your [personal and sensitive personal data we will do so in line with our retention policy wich you can ask for by emailing email@example.com
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 data.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require the organisation to change incorrect or incomplete data;
- require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where Effra Recruitment Solutions Ltd is relying on its legitimate interests as the legal ground for processing.
- Object to any decision, which significantly affects you, being taken solely by a computer or via another automated process
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
- Request that direct marketing by us to you is stopped:
Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken to both evidence our compliance, and to take steps to minimise the prospect of any data being processed in the future should it be received again from a third-party source.
If you wish to complain about this privacy notice or any of the procedures set out in it please contact:
The Director firstname.lastname@example.org or call 02033025771
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.
Additional policies or information
If you require additional information, please email email@example.com