Privacy Policy

Privacy Policy

Our Contact Details

 
Name: Understanding Recruitment Ltd

Address: Abbeyview, 38-40 The Maltings, St Albans, Hertfordshire, AL1 3HL

Phone Number: +44(0)1727 807 090

E-mail: gdpr@understandingrecruitment.com

Version: June 2022


Who we are and what we do

Understanding Recruitment Ltd 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.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. 

Our nominated representative is Lisa Booth.



The Type of Personal Information We Collect


Candidate Data
We currently collect and process the following information:

  • Name
  • Contact details such as email address and phone number
  • Photograph
  • Curriculum Vitae including employment history and educational details and other relevant information.
  • Links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website, IP address, Cookies.
  • Immigration status/Right to work
  • Start date/availability date
  • Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website or from links clicked on in emails from us
  • IP Address
  • The dates, times and frequency with which you access our services

On occasion we will collect and process the following information:

  • Home Address
  • National Insurance number
  • Sex/Gender
  • Date of Birth
  • Marital Status
  • References and referee details
  • Emergency contact details
  • Compliance documents regarding your personal service company
  • Financial information pertaining to you or your personal service company including bank details.
  • Extra information that you choose to tell us
  • Extra information that your referees choose to tell us about you
  • CCTV footage when you attend our offices


Client Data


We currently collect and process the following information:

  • Name
  • Contact details such as email address and phone number
  • Information and conversations relating to candidates introduced by Understanding Recruitment
  • Extra information that you choose to tell us
  • CCTV footage when you attend our offices
  • IP Address


Supplier Data


We currently collect and process the following information:

  • Name
  • Contact details such as email address and phone number
  • Extra information that you choose to tell us
  • CCTV footage when you attend our offices
  • IP Address


Website Users


When someone visits www.understandingrecruitment.com we use a third party service, Google Analytics and Hotjar, to collect standard internet log information and details of visitor behaviour patterns. 

We collect data on the 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. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. 


The Jobweb system that currently runs our website is capable of collecting the following details:

  • Account data such as: Candidate ID, Name, Email address, Registration date/time, Last login date/time
  • Profile data such as: Reference number (this is auto-generated (unique to each user) by the system), Address including longitude and latitude, Home telephone number, Mobile telephone number, CV synopsis, CV filename: filenames are auto-generated by the system (unique to each user) to enable cross-referencing of the profile with a specific CV file, Minimum salary, Maximum salary
  • LinkedIn profile URL
  • Twitter profile URL
  • Facebook profile URL
  • Candidate data history: records the counts of how many times a given candidate has been returned in the candidate search results, viewed, or been added to a folder
  • CV file: this includes the CV file itself as well as a reference to the CV file name which is stored in the database against the candidate’s account
  • Supporting files: there are additional documents the candidate may be able to upload to support their search for a job. 
  • Application CV file: this includes the application CV file, which is saved separately to the profile CV file, as well as a reference to the application CV file name which is stored in the database against the application record
  • Saved search data (including jobs by email alerts)
  • Saved job (wish list) data and the job ID: the ID of the job the candidate has savedo Date/time: the time stamp that the job was saved by the candidate
  • Email log: Date/time: the time stamp that the email was sent to the candidate
  • Email name: this will be the subject line for the email
  • Address To: the email address that the email was sent to (i.e. the candidate)

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.


How We Collect Personal Information and Why We Have It


How we collect Candidate Data

Most of the personal information we process is provided to us directly by you which may include:

  • Sending your CV to Understanding Recruitment or one of its employees
  • Applying to a job on the Understanding Recruitment website
  • Creating a profile on the Understanding Recruitment Website or signing up for job alerts
  • Providing a hard copy of your CV
  • Providing information directly to us as it has been requested in order to fulfil our legal or contractual obligations. 
  • Conversations on the telephone or video conferencing (which may be recorded)

We also receive personal information indirectly, from the following sources in the following scenarios:

  • Job boards where you have uploaded your CV and of which we subscribe
  • Professional profiles such as LinkedIn where you have marked yourself as open to opportunities or accept an InMail or connection request. 
  • Where you have applied to a job advert, advertised by Understanding Recruitment. 
  • The public domain, when searching for suitable candidates for a job role. 
  • Your referees may disclose personal information about you.


Why we collect Candidate Data

  • The main reason we collect and process candidate data is to provide our recruitment services to you and facilitate the recruitment process;
  • We store candidate details in order to contact you in relation to job opportunities that may be of interest to you and to keep a record of our conversations and meetings
  • We store candidate details in order to update you on a current job application
  • We store candidate details in order to stay up to date with your employment and skills.
  • Assessing data about you against current vacancies which we think may be suitable for you
  • Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you
  • Send your information to clients for opportunities when you have given us permission to do so. 
  • Allow us to fulfil our obligations to you arising from any contracts entered into between us
  • Allow us to fulfil our obligations to our clients in relation to your recruitment process
  • Allow us to fulfil any legal obligations in relation to your recruitment
  • Facilitate payroll and invoicing
  • Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you Before we do so, you will be given an option to opt-out of such communications and an option to unsubscribe will also be provided with each communication.
  • In order to provide you with personalised content on our website, with more relevant communication in our emails, and with a tailored service from our consultants, we track and record your usage and interaction with our website and emails. 


How we collect Client Data

We obtain client data either directly from you, when you contact us directly by phone and/or email or where we contact you through business development activities by either email and/or phone where a member of your organisation has given us your details. 


We may also collect client data from other sources such as:

  • The public domain such as an organisation’s website and other online sources during business development activities
  • Professional profiles such as LinkedIn
  • Conversations on the telephone or video conferencing (which may be recorded)

 

Why we collect Client Data

  • The main reason we collect and process candidate data is to provide our recruitment services to you and facilitate the recruitment process;
  • We store client details in order to contact you in relation recruitment services we provide or can provide to you
  • To keep a record of our conversations and meetings
  • Processing your data for the purpose of targeting appropriate marketing campaigns for our services


How we collect Supplier Data


We obtain supplier data either directly from you, when you contact us directly by phone and/or email or where we contact you through either email and/or phone where a member of your organisation has given us your details. 


Why we collect Supplier Data
 

  • We store supplier details in order to contact you in relation to our agreements
  • To obtain support and services from you
  • To perform certain legal obligations


Who Do We Share Your Personal Information With

 

  • We share your information with the appropriate employees of Understanding Recruitment
  • We may share this information with regulatory or law enforcement agencies, if we are required or permitted to do so. 
  • We share your data with our third-party service providers who perform functions on our behalf such as Bullhorn our CRM provider, Venn our website provider and Broadbean our job application provider, our IT providers, all of which we have entered into agreements with that they will not use your data outside the scope of the services they provide us.  
  • Clients or candidates to facilitate the job application process where the appropriate consent is obtained.
  • Third parties helping us by developing services and processes to optimise the Candidate selection process in order to improve the quality and efficiency of our recruitment services.
  • Prospective employers where you have provided Understanding Recruitment as a referee. 
  • Individuals and organisations who hold information related to your reference such as current, past or prospective employers.
  • Third party financial providers/banks or auditors where we are required to evidence services provided or meet regulatory and auditing requirements. 


Legal Basis for Processing Data


Under the General Data Protection Regulation (GDPR), the main lawful bases we rely on for processing the information mentioned above are: 
 

Necessary for the purposes of legitimate interests 


Article 6(1)(f) of the GDPR says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."

After undertaking a legitimate interest assessment, we do not believe that the processing of your data for the purposes we have outlined in the policy prejudice individuals. We believe that processing your data the way we do allows us to provide you with a more professional and efficient recruitment services. You do, however, have the right to object to us processing your information on this basis.


Candidate Data


As a recruitment business our main goal is to find the best talent and connect it to the best opportunities whilst building and maintaining relationships. As a candidate who has either applied to our job advert, responded to us on LinkedIn, directly given us your cv, uploaded your cv to a job board or is open to opportunities, we believe it is reasonable to think that you are happy with us collecting and processing your data to provide our recruitment services to you and assess your skills and qualifications against our list our vacancies. Without building relationships with candidates we are unable to function as a recruitment business and help you can other candidates develop your careers. 

We want to be able to present you with tailored job opportunities and relevant information to read regarding your market to help you on your job hunt. We believe it is reasonable based on the information you give us and the conversations we have regarding your skills and employment preferences to make sure that we send you the most appropriate content and identify the most suitable opportunities for you.


Client Data


In order for us to support you as our client and aid you in your search for talent, we believe it is reasonable for us to store your contact details as well as keeping records of our conversations, meetings and the past services.


Supplier Data


We believe that using and storing your personal information of individuals within your organisation in order to receive the services from you as one our supplies falls within the range of our legitimate interests.


Consent


In some circumstances, we may ask for your consent to process your personal data in a particular way, like submitting your CV to a client.

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 and we will keep records of the consents that you have given and withdrawn. 


Necessary for entering into, or performing, a contract 


In order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data; 


Necessary for compliance with a legal obligation 


We are subject to certain legal requirements which may require us to process your personal data.   We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;


How We Store Your Personal Information 


Understanding Recruitment takes the protection of your data seriously which is why we take reasonable and appropriate steps to protect the information that we hold from misuse, loss, or unauthorised access. We do this by having a range of appropriate technical and organisational measures in place. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. 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.


As mentioned in this policy, sometimes it will be necessary for us to share or transfer your information to other organisations in order to provide you with our services. Your data will be transferred to

  • to a cloud-based storage provider.
  • third parties (such as Suppliers)
  • to Clients within the UK, where applicable, who may, in turn, transfer your data internationally
  • to overseas Clients where applicable

We will therefore only transfer data outside of the European Economic Area (EEA) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

  • where you have consented to the data transfer.
  • by signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or
  • by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
  • transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or
  • where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract; or
  • To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.


How Long Do We Store Data


Candidate Data

 

  • As a candidate, we will Delete your personal data from our systems if we have not had any meaningful contact with you (active communication between us, either verbal or written)  for two years or for such longer period as we believe that the law or relevant regulators require us to hold your data.
  • Where you no longer wish for Understanding Recruitment to provide our services to you and have expressly indicated that you no longer wish for us to hold your data, then we will delete it from our systems, unless we believe that the law or relevant regulators require us to hold your data, which we will outline to you. 
  • Where we have supplied you with recruitment services such as representing you for an interview at one of our clients, or sending your CV to one of our clients, we are legally required to hold your data relating to you application for a period of one year past the date we last provided you our services.
  • Likewise, where you are successfully placed with one of our clients, either as a contractor or as a temporary worker, we are required to retain your details including your personal and company details, relating to your assignment for a period of 6 years past the last financial year, after the end of your assignment, in line with the Limitation Act 1980 (s.5) and to ensure we fulfil our legal obligations in relation to record keeping for the purposes of HMRC compliance.
  • Where you have been successfully placed with one of our clients as a permanent employee, we will hold your details relating to your placement for a period of 6 years past the last financial year in line with Limitation Act 1980 (s.5) and to fulfil our contractual obligations with our clients and legal obligations in relation to record keeping.
  • Where we are legally or contractually obligated to hold your personal details and therefore are unable to fully execute your erasure request, we will restrict and suppress your data and delete any data that is not pertinent to the legal or contractual reasoning.

Client Data

  • As a client we will retain your personal information in order to provide services to you and inform you of services we could potentially provide to you. If you expressly indicate that you are not interested in our services, then we will delete your personal information from our systems, unless we believe that the law or relevant regulators require us to hold your data, which we will outline to you.

 

Supplier Data
 

 

  • As a supplier we will retain your personal information in order to receive services from you. We hold your details for as long as our agreement dictates or for as long as we require your services, after which we will delete your personal information from our systems, unless we believe that the law or relevant regulators require us to hold your data, which we will outline to you.

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.


Direct Marketing 

If you become a candidate, client or supplier, we may use your personal information to send you information that we think may be of interest to you or your business. We send you this information under legitimate interest as a recruitment company as we believe certain relevant market information may be beneficial.

If you do not wish to receive any direct marketing material or communications after you submit or provide your details, you are able to unsubscribe by clicking the link in any of the emails sent to you or alternatively by contacting us at gdpr@understandingrecruitment.com and writing UNSUBSCRIBE or by letting your consultant know that you do not wish to receive direct marketing material.

If you change your mind about being contacted by us in the future, or change address, or if any information that we hold about you is inaccurate or out-of-date, please let us know by emailing or writing to us. We may need to check your identity before amending your information.



Your Data Protection Rights


Under data protection law, you have rights including:

  • Your right of access - You have the right to ask us for copies of your personal information. 
  • Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 
  • Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. 
  • Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances. 
  • Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.
  • Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at gdpr@understandingrecruitment.com if you wish to make a request.

 

How To Complain


If you have any concerns about our use of your personal information, you can make a complaint to us at gdpr@understandingrecruitment.com

You can also complain to the ICO if you are unhappy with how we have used your data.


The ICO’s address:            

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF


Helpline number: 0303 123 1113

ICO website:https://www.ico.org.uk


Changes To Our Privacy Notice  

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.


Contact  

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to gdpr@understandingrecruitment.com