This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.
Changes to the data protection law
From the 25th of May 2018, we will be processing your personal data in accordance with the General Data Protection Regulations (GDPR). Up until that point we will continue to process your personal data in accordance with the existing Data Protection Act 1998 (DPA). This notice is written to comply with both the DPA and the GDPR.
Information we may collect from you
You may give us information about you by filling in forms on our site, Steele-Dixon or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our site, subscribe to our service, and participate in discussion boards or other social media functions on our site. It also includes when you enter a promotion or survey, during the course of any other activity commonly carried out on our site and when you report a problem with our site. The information you give us may include (but not be limited to) your name, address, email address and phone number, personal description, job history, qualifications and photographs.
With regard to each of your visits to our site we may automatically collect the following information:
Personal data requested may also contain “special category data” as defined in the GDPR and this may include racial or ethnic origin, sexual orientation and health (ie. whether you are registered disabled). You can decide whether you wish to share this information with us. Not sharing this information does not prevent you from registering or using our services.
Where else may we get your data from?
External CV Databases
As part of our service we may obtain your personal details and CV as from a number of different job boards or CV databases that we have access to. We use these details in order to match client vacancies we have against suitable candidates. As part of our internal processes for this service we will contact you prior to passing on your CV and details to potential employers. As appropriate you may ask us to remove or update the details we have obtained via these sources.
Why do we collect this information?
We collect information about you in order to provide you the best careers advice possible tailored to your specific preferences or experience. The information is also necessary for us and employers to match you against any opportunities that they have.
In addition, we sometimes use the anonymous personal data (ie. with all personal identifiers removed) for the purposes of research, industry trend reporting and for our own planning purposes and future developments.
Where we store your personal data
Protection of your personal data
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.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data through the use of security measure like the use of an SSL certificate, we cannot guarantee the security of your data transmitted to our site and any transmission is at your own risk.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, including all necessary technical and organisational measure to protect your data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access and against all other unlawful forms of processing;
What do we do with your information?
The personal information you provide helps us with providing more tailored advice and opportunities depending on your preferences. Our aim is to provide you with only content relevant to you. You may unsubscribe to these emails or change your profile information at any time either via the site or through the link provided at the bottom of each email.
To be more specific your information may be used in one or more of the following ways:
Additionally information we receive from other sources may be combined with information you give to us for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. Although usage will be limited to the original purpose for which we obtained your data unless we have your consent otherwise.
We may share your information with selected third parties including:
Business partners, suppliers, clients and subcontractors for: (1) the performance of any contract we enter into with them or you or (2) the purpose of sourcing your employment or engagement with a third party.
Automated processing and profiling
We use the information you provide to make automated decisions solely in the capacity of delivering you content based on your stated preferences. Personal data may be matched against vacancies to provide relevance to you in the form of job alerts. However you may change your preferences to amend what content or vacancies are filtered.
No judgements or decisions are made of an individual’s suitability for a particular role solely as a result of any automated processing that may take place.
Legal basis for processing your data
The legal basis for processing under GDPR is outlined below:
Candidate personal data held by us
Contractual necessity (Article 6(1)(b)), legitimate interest (Article 6(1)(f)) and consent Article 6(1)(a)
Client or employer related personal details held by us
Contractual necessity (Article 6(1)(b)), legal obligation (Article 6(1)(c) and legitimate interest (Article 6(1)(f))
On occasion we may process you data on the basis of consent (such as special category data), or the sending of promotional or marketing material not related to job opportunities or where there is a facility to link to your Social network.
It may be necessary for us to process your data in order to fulfil a contract with you such as sending your CV and details to an employer for a particular role you have applied for or are interested in.
In the case of a Client or Supplier we may need to process your personal data for the purpose of fulfilling out contractual obligation with regards to the service or product delivery.
We may also process your data when it is in our legitimate interest to do so and the processing does not impact on any of your data protection rights. Our legitimate interests include:
You have the right to object to the processing of your data under legitimate interest should you feel that such legal basis is not warranted or feel that it overrides any of the rights that you may have.
How long we keep your information for
Personal information, CVs and cover letters: for a maximum of 30 months
Employer/client related personal details: For the length of our relationship with you plus 6 years (Limitation Act (1980) in case the case where there may be a dispute. Some information may be required to be retained longer due to legal obligations (eg. HRMC).
Your rights over your information
You have the right to not have your personal data processed for unrelated marketing purposes. We will usually inform you (before collecting your data) 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, and obtain your consent.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
For emails and alerts from us you can stop receiving these by clicking the unsubscribe link in the emails sent or change your preferences.
By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate.
You can also ask us to give you a copy of the information and to stop using your information for a period of time if you believe we are not doing so lawfully.
To submit a request by email, post or telephone, please use the contact information provided above.
In addition to the above you have the following rights under GDPR:
You can withdraw consent at any time where consent has been relied upon. If consent is the sole legal basis for processing, we will stop processing the data after the consent is withdrawn. The data will then be placed in a restricted processing mode until you have asked to exercise your right to erasure or the personal data falls outside stated retention period (whichever comes first).
Our communications with you
We will periodically communicate with you by email, post, telephone or device notifications for the purposes of delivering our services to you. The legal purpose for which is under the legitimate interest provision under both GDPR and the Privacy and Electronic Communications Regulations (PECR).
However, should you be concerned about the content of these communications (such as unwanted marketing communications or simply want to change the way we communicate with you please log into your profile on the relevant website and change your preferences, or use the relevant unsubscribe link. Alternatively you can contact us by telephone or letter at the details provided above.
You may contact us for any of the described purpose above. Our main address is:
Mulberry Court, Crown Road, Wheatley, OX33 1UL
You can contact us by post at the above address, or by via email at email@example.com or by telephone on +44 (0)1235 536440.
We are not required to have a data protection officer, so any enquiries about our use of your personal data should be addressed to the contact details above asking for the person responsible for data protection.
Changes to this privacy notice
Your right to complain
If you have a complaint about our use of your information you can do so with the relevant supervisory authority within the EU to which you are a resident, whom may refer the complaint to the UK supervisory authority.
Complaints in the UK can be made to the Information Commissioner’s Office via their website at www.ico.org/concerns or write to them at:
Information Commissioner’s Office