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PRIVACY POLICY

Swan Recruitment Limited is a recruitment business which provides work seeking services to its clients and candidates. We must process personal data (including sensitive personal data) so that it can provide these services – in doing so; we act as a data controller.

You may give your personal details to us directly, such as on a job application, registration form, via our website, or we may collect them from another source such as a job board. We must have a legal basis for processing your personal data. For the purposes of providing you with work seeking services and/or information relating to roles relevant to you we will only use your personal data in accordance with the terms of the following statement.

Legal bases for processing your data

Legitimate Interests

We believe that we have a legitimate interest in processing your data for the purposes of providing work seeking services to both our clients and candidates. We believe that this helps us provide you with a more personalised service and that it is in everybody’s interest for us to do so.

Candidates

We believe that it is reasonable to expect that if you are looking for employment or have posted your CV onto a job board or networking site, you are happy for us to collect and use your data to offer or provide you with work seeking services. This can include forwarding your details to prospective employers or matching your details against our open vacancies. Prospective employers might want to verify certain aspects such as references and qualifications. We need to be able to do this to function as a profit-making organisation.

We have to comply with various legal, regulatory and tax obligations and we have a legitimate business interest in doing so. Therefore we may share your data with the appropriate authorities to meet these obligations.

To ensure we can provide services to you we will need to use your data for internal processes such as payroll or invoicing.

We want to help you find a job. We believe that sending you job recommendations and relevant market intelligence will facilitate this. We will process your data to send you appropriate content.

Clients

To ensure that we can provide you and your organisation with the best possible service we store details of the organisation and its contacts as well as notes of conversations, emails, meetings and previous jobs and recruitment activity. We believe that this falls within our legitimate interest in providing recruitment services to you.

Consent

In certain cases, such as processing sensitive data, we will need to obtain your consent. In these cases:

  • You have to give your consent freely
  • You have to know what you are consenting to
  • You should be able to control your consent
  • We will keep a record of your consent
  • You have the right to withdraw your consent
  • Establishing, exercising or defending legal claims

Occasionally we may need to process your data when it is necessary for the establishment, exercising or defending of legal claims or whenever the courts are acting in their judicial capacity.

Collection of personal data

Candidates

During the course of providing you with work seeking services we may collect some or all of the following types of personal data.  The reason we do this is to enable us to provide the best service we can to help you find your next job. The following list is not exhaustive and is in addition to any data that we are required by law to process:

  • Name
  • Contact details
  • Sex/gender
  • Date of birth
  • Education
  • Employment history
  • Immigration status
  • Nationality
  • Copy of passport / ID card / other form of identification
  • Tax information such as social security numbers
  • Details of criminal convictions where applicable to the role
  • Current salary and package
  • Any further information that you tell us included in future employment preferences
  • IP addresses
  • CCTV footage if you enter our premises
  • Dates that you make contact with our organisation

Clients

We will collect data that will help us ensure that the relationship between our organisations runs as smoothly as possible. This will normally be restricted to name, telephone number and email address of individual contacts. We may also hold IP addresses if you visit our websites and we may hold CCTV footage if you visit our premises.

How we collect your personal data

Candidates

We collect personal data from you in three ways:

  1. Personal data that you give us
    We need to know certain information about you in order to provide work seeking services to you. This will enable us to make better matches and to identify the most appropriate roles for you. The ways in which you can provide us with this information includes:
    Registering on our websites
    Sending us a copy of your CV electronically or by post
    Applying for a role via a job board which then redirects you to our website
  2. Personal data that we receive from third parties
    We may receive personal data about you from third parties and these can include:
    Our clients may share information about you
    Your referees may share information about you
    We may obtain data about you from websites such as job boards and LinkedIn. Through social media channels
  3. Personal data that we receive automatically
    We may automatically collect data about you as a result of you visiting our website and clicking of emails.

Clients

We collect personal data from you in three ways:

  1. Personal data that you give us
    To help us provide the best service to you and send you the most appropriate candidates we receive data as follows:
    You contact us by phone or email
    We contact you by phone or email, either during the normal course of business or as a result of our business development efforts
  2. Personal data we receive from other sources
    We may seek and obtain additional information about you as part of our business development and due diligence processes.
    From offline and online media
    Delegate lists from meetings, events and conferences
  3. Personal data that we receive automatically
    We may automatically collect data about you as a result of you visiting our website and clicking of emails.

How we use your personal data

Candidates

We use your data for a number of purposes:

  1. Work Seeking Services
    We provide work seeking services to candidates. We want to connect you to relevant opportunities as they arise. We may use your data in the following ways if we deem it necessary to do so for our legitimate interest. The ways in which we might use and process your data is as follows. Again this list is not exhaustive:

    1. Submitting your data to prospective employers to apply for jobs
    2. Assessing your data against open vacancies to determine your suitability
    3. To provide you with work seeking services
    4. Storing your details on our database so that we can contact you in relation to future vacancies
    5. To provide you with job alerts and other work seeking related communications
    6. To enable us to meet our obligations of any contracts between you and us
    7. To enable us to meet our obligations of any contracts between us and third parties with regard to your recruitment
    8. Facilitating of payroll and invoicing processes
    9. Verifying details that you have provided (e.g. references, qualifications and criminal convictions)
    10. Complying with our legal obligations
  2. Marketing Activities
    Where you have previously contacted us (such as registering on our web site, submitting a CV, applying for a job) we may send you details of recruitment related services as we believe that this will be beneficial in your job search particularly where we send you details of vacancies similar to the one you specifically applied for. We may also ask you to participate in salary surveys and job related questionnaires to provide us with benchmarking data to better advise in your job search. For other marketing we will need your consent.
    If you do not wish to receive any marketing communications from us, you can withdraw your consent by unsubscribing at any time.
  3. Sensitive Personal Data
    We may need to collect sensitive personal data such as medical information and criminal convictions if required for a specific role. We will only do this with your explicit consent. You may withdraw your consent at any time.
  4. To help establish, exercise or defend a legal claim
    Occasionally we may need to use your data to establish, exercise or defend a legal claim.

Clients

We use your data for a number of purposes:

  1. Recruitment Services
    Our primary function is to provide you recruitment services including presenting you with candidates; providing market intelligence such as salary surveys; and the provision of recruitment process outsourcing services. To enable us to provide these services we will process your data in the following ways:

    1. Storing your data on our database so we can contact you in relation to recruitment activities
    2. Recording notes of conversations and meetings
    3. For targeted marketing campaigns
    4. Customer satisfaction surveys
  2. Marketing Activities
    As a matter of course we shall not seek your consent when sending marketing materials such as our salary surveys to corporate email addresses. If you wish to opt out of receiving marketing information you can unsubscribe from receiving them at any time.
  3. To help establish, exercise or defend a legal claim
    Occasionally we may need to use your data to establish, exercise or defend a legal claim.

Who we share your personal data with

We share your data with a variety of other parties during the course of conducting our business, in a number of ways, for a number of reasons.

They are as follows:

Candidates

  • Our group companies
  • Our clients and other recruitment businesses in the performance of finding suitable employment for you
  • Third party IT companies with whom we are contracted to and have appropriate data processing agreements
  • Third party services providers who perform work on our behalf (e.g. auditors, lawyers, IT providers etc.)
  • Tax and local authorities to enable us to comply with laws and regulations
  • Marketing technology providers
  • Job boards and job aggregators, where it helps us find you work
  • Managed Service Providers where our clients have outsourced their recruitment process

Clients

  • Our group companies
  • Third party IT companies with whom we are contracted to and have appropriate processing agreements
  • Third party services providers who perform work on our behalf (e.g. auditors, lawyers, IT providers etc.)
  • Tax and local authorities to enable us to comply with laws and regulations
  • Marketing technology providers

How we safeguard your personal data

We take all reasonable steps to ensure that your data is safe and protected from misuse, loss or unauthorised access. We ensure this by implementing a range of technical safeguards and operational processes. We also have processes to deal with any suspected data breach.

If you suspect that your data has been misused, or has been compromised please contact us immediately at craig.bell@swanrecruitment.com

Retention Policy

We will not retain your data longer than we need it. In certain cases we are required to hold your data to comply with tax, legal or regulatory issues, for instance payroll records. Subject to this, we will delete your data if we haven’t had any relevant contact from you (or for clients, the company you work for or with) for a three year period.

If you supply your services via a third party, then the relevant contact shall be with that third party. Where that third party informs us that they no longer have a relationship with you, we will hold your data for a period of three years from that point.

For the purposes of this policy, relevant contact means:

  • Communicating with us via email, telephone or mail
  • Submitting your CV or applying for a role
  • Registering and logging onto our websites
  • Completing any surveys
  • Clicking through from any of our marketing communications
  • Your rights
  • Please be aware that you have the following data protection rights:
  • The right to be informed about the personal data that we process on you;
  • The right of access to the personal data that we process on you;
  • The right to rectification of your personal data;
  • The right to erasure of your personal data in certain circumstances;
  • The right to restrict processing of your personal data;
  • The right to data portability in certain circumstances;
  • The right to object to the processing of your personal data that was based on a public or legitimate interest;
  • The right not to be subjected to automated decision making and profiling; and
  • The right to withdraw consent at any time.

Where you have consented to us processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting our Data Controller Craig Bell at Craig.Bell@swanrecruitment.com

Overseas Transfers

We are an international business. We provide work seeking services to candidates and clients around the world, therefore to enable us to give you the best service possible we will sometimes need to transfer and store your data internationally. This could be:

  • Between our group companies
  • To overseas clients
  • Our clients may transfer your data internally
  • To data storage facilities
  • To our suppliers where appropriate

The company may transfer only the information you provide to us to countries outside the European Economic Area (“EEA”) for the purposes of providing you with work seeking services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises of the EU member states plus Norway, Iceland and Liechtenstein.

UPDATE TO SWAN’S PRIVACY POLICY

As part of Swan’s ongoing commitment to our clients, we wanted to make you aware that from the 25th May 2018, the new EU General Data Protection Regulation (GDPR) will be coming into effect across all European member states.
In order to comply with the new requirements of this law, ensuring that your data is processed and stored safely and to enable us to serve you with recruitment services, Swan has updated their Privacy Policy.
What this means for you:
  • Further protection of your personal data;
  • Standardisation of the European data protection.
If you are happy for Swan to carry on with the service we provide to you, there is no need to do anything further. However if you would like for us to remove your details from our database, please reply to this mail and confirm that this is your wish.
Thank you for using Swan Recruitment and we look forward to working with you in the future.
The SWAN Team

Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact Data Controller Craig Bell at craig.bell@swanrecruitment.com

You also have the right to raise concerns with the 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.

Our contact details

By post: Swan Recruitment Ltd. 3 Acorn Business Centre, Northarbour Road, Portsmouth PO6 3TH. UK.

Data Controller : Craig Bell

Craig.Bell@swanrecruitment.com