TERMS AND CONDITIONS OF THE CONTRACT: YOUR RIGHTS UNDER GDPR & EPRIVACY
Gravitas Recruitment Group (company number 06959984) is committed to protecting the privacy of our candidates, clients and users of our website. We want to provide a safe and secure user experience. We will ensure that the information you submit to us via our website or through any of our offices or other international websites or offices is only used for the purposes set out in this policy.
This notice sets out the way in which we, Gravitas Recruitment Group, will collect and use information about you in a way that is consistent with our responsibilities and your rights under relevant privacy law. Please read it carefully so that you understand how we will use your information.
Your privacy is important to us and we take it very seriously. We want to help everyone who uses Gravitas Recruitment Group Limited (Gravitas) services to get the most out of them. This policy covers all our brands – Gravitas Recruitment Group Limited, and Gravitas Talent Solutions and their associated products and services.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate. Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
The policy below lays out in simple English how the GDPR and the current ePrivacy Directive (soon to be updated) applies to the way Gravitas handles your personal data. Our aim is to be responsible, relevant and secure when using your data. Gravitas specialises in providing Recruitment Services within the Technology sector, and professional networking within the Technology sector. Our expectation is that individuals giving consent share these aims and objectives. If this is not your expectation, please do not consent. Providing consent indicates that you have read and understood the terms and conditions of the policy.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.
Please take a moment to read through what information we collect about you, who we share it with and how they might use it.
FOR THE PURPOSES OF DATA PROTECTION LEGISLATION IN FORCE FROM TIME TO TIME THE DATA CONTROLLER IS GRAVITAS RECRUITMENT GROUP OF 6 BEVIS MARKS, LONDON, EC3A 7BA.
WHO WE ARE AND WHAT WE DO
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We collect the personal data of 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;
• Supplier contacts to support our services;
• Employees, consultants, temporary workers;
We collect information about you to carry out our core business and ancillary activities.
THE INFORMATION WE COLLECT AND HOW WE USE IT
This is information about you that you give us by filling in forms on our site www.gravitasrecruitmentgroup.com (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and if you report a problem with our site.
The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website
INFORMATION WE COLLECT ABOUT YOU WHEN YOU VISIT OUR WEBSITE
With regard to each of your visits to our site we will automatically collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, [browser plug-in types and versions,] [operating system and platform,] [OTHER]; information about your visit, including [the full Uniform Resource Locators (URL),] [clickstream to, through and from our site (including date and time),] [products you viewed or searched for’] [page response times,] [download errors,] [length of visits to certain pages,] [page interaction information (such as scrolling, clicks, and mouse-overs),] [methods used to browse away from the page,] [OTHER] and any phone number used to call our customer service number.
INFORMATION WE OBTAIN FROM OTHER SOURCES
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
• Personal data may be acquired from job boards (Adzuna, Bijobs, Career builder, ContractRecruit, CVLibrary, CWJobs, IT Job Pages, Job Rapido, JobserveXML, Jobsite, Monster, Recuit.net, TipTopJob, Totaljobs, Trovit, Zoek) and social media sites (specifically Linkedin, Facebook, Twitter, Github, Stack Overflow)
• Should you wish to withdraw consent at any time, please email firstname.lastname@example.org
• Please note that as Gravitas Recruitment Group use the latest Recruitment Technology, it is important that you also withdraw your consent from all other public sites. Should Gravitas acquire your personal details again you will be informed and asked for formal consent to process your personal information.
This information is held, used and disclosed by us as follows:
1. to provide our services to you;
2. to maintain our business relationship, where you are a user of our website, a client or candidate;
3. to enable you to submit your CV for general applications, to apply for specific jobs or to subscribe to our job alerts. Please see the separate section on your CV below which outlines additional uses and disclosures;
4. to match your details with job vacancies, to assist us in finding a position that is most suitable for you and to send your personal information (including sensitive personal information) to clients in order to apply for jobs;
5. to answer your enquiries;
6. to direct-market products and services, advise you of news and industry updates, events, promotions and competitions, reports and other information. Where we do so, you will be able to unsubscribe from such communications;
7. to fulfil contractual obligations with our clients
8. to trusted third parties where we have retained them to provide services that you or our clients have requested, such as reference, qualification and criminal reference checking services (as required), verification of the details you have provided from third party sources, psychometric evaluations or skills tests. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality as Gravitas Recruitment Group;
9. to third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems, research and mailing houses and function co-ordinators. These third parties comply with similar undertakings of privacy and confidentiality as Gravitas Recruitment Group;
10. if Gravitas Recruitment Group or its business merges with, acquires, or is acquired by another business or company, we may share personal information with the new owners of the business or company and their advisors and if this happens, you will be sent notice of such event;
11. we may also release personal information to regulatory or law enforcement agencies, if they require us to do so. We will also disclose your information where we are permitted and requested to do so by law; and
12. we may also seek your consent to collect, hold, use and disclose your personal information for any other purpose not listed above.
CURRICULUM VITAE ("CV")
We give you the option of submitting your CV via our website or by providing your CV to one of our consultants. You can do this either to apply for a specific advertised job or for consideration by our recruitment consultants for positions as they come up. Your CV will be stored in the Gravitas Recruitment Group database, and will be accessible by Gravitas Recruitment Group recruitment consultants in the UK.
You can update your CV at any time, simply by following the same procedure to submit a new CV. Your old CV will automatically be archived providing the submission details remain the same (for example you submit both CVs using the same email address or you advise the relevant contact of your new submission).
Please note that clicking on links and banner advertisements may result in your transferral to another website - where data privacy practices may be different to that of Gravitas Recruitment Group. Visitors should consult the other websites' privacy policies as we are not responsible for, and have no control over, information that is submitted to or collected by these third parties.
Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. Therefore, by browsing our website and communicating electronically with us, you acknowledge and agree to our processing of personal data in this way.
WHAT IS THE PURPOSE AND LEGAL BASIS FOR PROCESSING?
We use information held about you in the following ways:
• To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
• To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
• The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies
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 if 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 requires to hold information on to you 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. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).
OUR LEGITIMATE BUSINESS INTERESTS
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.
We are retained by leading organisations to identify and place senior executive talent. We have identified you as an executive that would be of interest to our clients. In order to fulfil our contractual obligations with our clients, we would like to be able to keep you informed about relevant opportunities, and ensue the information we are providing is correct.
This legitimate business interest is appropriate when data is used in a way that can be reasonably expected and with minimal privacy impact. Gravitas Recruitment Group take your privacy very seriously, and accept additional responsibility to ensure the accuracy of the Personal Information that we hold, to be considerate and protective of your rights and interests.
Gravitas Recruitment Group have thought carefully about the rights, interests and freedoms of the individual, by completing a Legitimate Business Interests Assessment. Gravitas Recruitment Group have balanced your rights against the legitimate business interest of Gravitas Recruitment Group’s responsibilities to our candidates and clients. This processing of personal data has been deemed necessary in order to complete our objective, to match your details with job vacancies, to assist us in finding a position that is most suitable for you and to send your personal information (including sensitive personal information) to clients in order to apply for jobs
Gravitas Recruitment Group will not process data if it is deemed that the data subject would not reasonably expect the data to be processed, or, if the processing is deemed to cause unjustified harm.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
OTHER USES WE WILL MAKE OF YOUR DATA:
• Use of our website;
• to notify you about changes to our service;
• to ensure that content from our site is presented in the most effective manner for you and for your computer.
We will use this information:
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Gravitas Recruitment Group is committed to protecting the privacy of our candidates, clients and users of our website. We want to provide a safe and secure user experience.
We have taken numerous technical security measures to prevent the accidental loss, destruction or unauthorised disclosure of personal information, including (but not limited to): Encryptions, Permission controlled access restrictions and IP address restrictions.
WHO WILL HAVE ACCESS TO THE DATA?
• The recipients of personal data are limited to Gravitas Recruitment Group
• We work with the following data processors: Bullhorn, Giant Precision, Twitter, Linkedin, Facebook, Google Analytics, and Sage. We only work with GDPR compliant suppliers
• We will only make your personal information visible to the organisations we are working with when we put you forward for an opportunity. We will ask your permission before putting you forward for an opportunity. You will be made aware of the organisation with which we are making your personal data visible.
WHO WILL WE SHARE YOUR PERSONAL INFORMATION WITH
• Your data will not be shared with any third parties without your prior knowledge, but may be used by us to help a selected, GDPR compliant and professionally relevant group of industry suppliers to share their knowledge and insights with you through our branded channels
• Your personal data will not be shared with any third parties unconnected with Gravitas.
WHERE WE STORE AND PROCESS YOUR PERSONAL DATA
• Gravitas has advised all parties that data may not be transferred outside of the UK without submitting satisfactory proof of their safeguarding methods and proof of a certified privacy shield
• Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; 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.
HOW LONG WILL THE DATA BE KEPT FOR?
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
• prior to making an introduction we check that we have accurate information about you
• we keep in touch with you so you can let us know of changes to your personal data]
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
• the nature of the personal data;
• its perceived accuracy;
• our legal obligations;
• whether an interview or placement has been arranged; and
• our recruitment expertise and knowledge of the industry by country, sector and job role.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
• The Retention period for personal data is 5 years. We have chosen 5 years because it is the average length of time a UK Manager remains in post.
• Gravitas will be required to deactivate personal data after the relevant retention period, or when they are in receipt of a data subjects request to do so, whichever is the earlier. The data subject has the right to change their mind and withdraw consent at any point during the retention period
• After a period of 2 years from providing consent we will seek confirmation that you are still happy for us to continue to hold your data.
• Gravitas Recruitment Group may need to retain your personal data for up to 7 years, in order to comply with other government or tax legislation.
• Please be aware that Gravitas Recruitment Group may not be required or able to delete all personal details, particularly where your file also holds information about our clients or financial information that we need to keep for periods of up to six years, i.e. that relate to tax matters. Where we are unable to comply with your request we will provide reasons for failing to do so.
WHEN WE WILL DISCLOSE YOUR PERSONAL INFORMATION TO THIRD PARTIES:
• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Gravitas Recruitment Group 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.
THE LAWFUL BASIS FOR THE THIRD PARTY PROCESSING WILL INCLUDE:
• Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
• satisfaction of their contractual obligations to us as our data processor;
• for the purpose of a contract in place or in contemplation;
• to fulfil their legal obligations.
RIGHTS AND RETENTION, UPDATING AND REMOVAL OF PERSONAL INFORMATION
You have the right to ask us not to process your personal data for 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 we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com
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.
The GDPR provides you with the following rights. To:
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party in certain formats, if practicable.
• The right to be informed
• The right to be forgotten
• The right to object to automated decision making
(We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process
• Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Access to information
• The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
• Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force). Prior to 25th May 2018 any access request under the Data Protection Act will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
• A subject access request should be submitted to firstname.lastname@example.org. No fee will apply once the GDPR comes into force.
GRAVITAS RECRUITMENT GROUP RESPECTS AND CONFIRMS THE FOLLOWING RIGHTS TO EACH DATA SUBJECT:
Gravitas Recruitment Group appreciate the importance of ensuring Personal information is accurate and up to date, should you wish to update your personal details please email email@example.com
You have the right at any time to ask us for a copy of the information supplied by you that we hold. We may ask you to verify your identity and for more information about your request.
If you would like to make a request for information, please contact firstname.lastname@example.org. You also have the right to ask Gravitas Recruitment Group to stop using your information. However, if this involves a request for deletion of your file, please be aware that we may not be required or able to do so, particularly where your file also holds information about our clients or financial information that we need to keep for periods of up to six years, i.e. that relate to tax matters. Where we are unable to comply with your request we will provide reasons for failing to do so.
• Gravitas Recruitment Group is an equal opportunities employer and a company committed to diversity. This means that all job applicants and members of staff will receive equal treatment and that we will not discriminate on grounds of gender, marital status, race, ethnic origin, colour, nationality, national origin, disability, sexual orientation, religion or age
• As part of our commitment to equal opportunities we may from time to time use information provided by you for the purposes of diversity monitoring. All such information will be used on an anonymised basis.
ENQURIES, ISSUES AND COMPLAINTS
If, at any time, you have questions about Gravitas Recruitment Group's data subject rights, or would like to make a request for more information, please feel free to e-mail us at email@example.com, or call your local office to speak to one of our representatives.
• The Data Controller is Gravitas Recruitment Group Limited. It is Registered in the UK Company Number 06959984
• Level 3, 6 Bevis Marks, London, EC3A 7BA
• The Data Controller’s representative is the Group Commercial Manager
• You can call us on 0203 640 9800
• Gravitas Recruitment Group is registered as a Data Controller with the Information Commissioner’s Office Certificate Number ZA00443
• Should you have any questions or wish to withdraw consent at any time, please email firstname.lastname@example.org
If, at any time, you have questions or concerns about Gravitas Recruitment Group's online privacy commitment, please feel free to e-mail us at email@example.com, or call your local office to speak to one of our representatives.