Due to the introduction of the General Data Protection Regulation (GDPR), we have updated our privacy/data policy to reflect our responsibilities to you. This policy details how we will use your information and your rights relating to your data.
Please read the following carefully to understand how we will treat your personal data. This policy may change and you should check this page from time to time to ensure you are happy with the changes.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
General Data Protection Regulation (GDPR) – Information & Guidance
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.
Your rights under the GDPR are set out in this notice and will apply once the 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.
For the purposes of data protection legislation in force from time to time the data controller is Brevere Group.
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 also provide the following other services: outsourcing, contracting and marketing services.
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.
Information you give to us or we collect about you
This is information about you that you give us by filling in forms on our site (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 when you report a problem with our site.
The information you give us or we collect about you may include your name, address, demographic information such as post code, 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, employment details, employment preferences, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website,
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, and any relevant social media sites. In this case we will inform you, by sending you an email and link to 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 work 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.
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.
Information about your visit, including the full Uniform Resource Locators (URL), products/jobs 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 and any phone number used to call our customer service number.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
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.
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.
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.
Information and documentation to establish your right to work is processed by us as we are legally obliged to do so.
In respect of medical information, the basis for us processing this will depend on the circumstances, but will usually be for one of the following reasons: it is necessary to protect health and safety or to prevent discrimination on the grounds of disability or where consent has been obtained, if required.
Information in relation to criminal record checks, which are relevant for some roles, will be processed on the basis that it is necessary for us to comply with the law or consent will be obtained, if required.
Once a position has been found for you, we will process your personal data, including financial information, for the purpose of you entering into a contract to fulfil your role and to enable us to pay you, depending on the specific contractual arrangements and circumstances.
For the purposes of paying you, where relevant, we are legally obliged to provide information to HMRC.
Once a placement has been secured, we may also process your data on the basis of our legitimate interests i.e. for administrative purposes.
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 required to hold information on 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 are 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.
To deliver our ancillary services we need to contact candidates on a regular basis, through various routes such as email, phone, job alerts and other relevant notifications
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:
You can visit this Site without telling us who you are or revealing any information about yourself, including your email address. In this case, our Web server may collect the name, address, the IP address and domain you used to access this Site, the type and version of browser and operating system you are using, and the web site you came from and visit next. This information is used by us and our business partners to measure the number of visits, average time spent, page views, and other statistics about visitors to this Site in general. We may also use this data to monitor site performance for systems administration purposes, to make this Site easier and more convenient to use and to report information in aggregate form to our advisers (e.g. how many visitors log in to this Site).
Personal Information Collection, Use and Distribution to Third Parties Generally
There are times when we may ask you for or you may choose to provide information about yourself or your business to assist us in meeting your various needs. This information may be used for the following purposes: answering your questions, providing you with services you have requested, giving producers and developers of the Site information that is useful in determining appropriate new features, content and services, to provide advertisers with aggregate, not individual, information about our customers, or informing you of additional services or opportunities provided by Brevere Group or by our business partners, that may interest you.
To provide these services, we may need to ask you directly to provide, among other things, your name, mailing address, postal code, email address and phone number (“Registration Information”). You may also elect to apply on-line to a job posting (free of charge) OR to purchase one of our services. Purchasing services with us may require us to gather additional personal information for invoicing purposes.
At times, we also conduct on-line surveys to better understand the needs, profiles, and experience of our visitors. You will be given the option to participate in such surveys. Unless you request to receive the results of the survey via email, no personal information is requested during such surveys and all information is used on an aggregated basis only. If, during the registration process, you indicate you would like us to keep you updated on new site developments and information about our services or about offerings from Brevere Group, we will send you these updates by email.
If you contact Brevere Group we may keep a record of that correspondence. We may collect the email addresses of those who communicate with Brevere Group via email. We use the information provided only so that we may respond to the email. We do not knowingly solicit information from children and we do not knowingly market our services to children.
When you provide personal information to us, we may communicate and disclose it to third parties for the purpose of fulfilling, servicing and completing your requests and the transactions related to it. These third parties may be in the UK or in other parts of the world.
By registering with Brevere Group, you agree that your information may be shared with third parties for the purpose of fulfilling, servicing and completing your requests and transactions related to it as required. In addition, we, on occasion, enter into partnerships with third parties who offer products and services which we believe may be on interest and benefit to some users of the site. In such cases, Brevere Group may provide information to these third parties so that you can be informed of such products and services. If you do not wish to be included in any such programme, please email email@example.com to inform us and you will not be included.
We may also aggregate statistics that we gather about the visitors to the Site, sales, traffic patterns, and services and provide these statistics to third parties; however, when we do, these statistics will not include any personal information that identifies individuals.
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.
How we hold the information
All the personal data we have is stored on our database in the UK.
How Is Your Personal Information Secured and Protected?
Disclosure of your information
Your CV and related information will be shared or sent to prospective employers and our clients. Once you have secured a placement, additional information will be provided to them to enable the placement to proceed. Such employers and clients will usually be located inside the European Economic Area (EEA) but may be outside of the EEA. Personal data shall not be transferred to a country or territory outside the EEA unless that country or territory ensures an adequate level of protection or the appropriate safeguards are in place for your rights and freedoms. Before such a transfer takes place outside of the EEA, we will provide you with further information concerning this.
Other trusted third parties that we may share your data with are as follows:
HM Revenue and Customs, pension scheme providers, legal advisors and other companies for the purpose of undertaking pre engagement checks for the role or for paying you.
Any employee of Brevere Group both in the EEA and outside of the EEA.
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 Brevere 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.
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.
You have the right at any time to ask for a copy of the information about you that we hold. If you would like to make a request for information please email firstname.lastname@example.org
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.
Retention of your data
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.
Withdrawal of consent
If you have provided us with your consent to process your data, for the purpose of using our services and us finding you suitable work, you have the right to withdraw this at any time. In order to do so you should contact us by emailing email@example.com
If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance or directly to Information Commissioners Office at https:\\ico.org.uk\concerns.
Please address any questions, comments and requests regarding our data processing practices to David Jones, Managing Director – firstname.lastname@example.org
If you decide at any time that you do not want to receive any updates you have subscribed for just send an email message to email@example.com indicating your preference not to receive updates. If you are unsure whether we have a record containing your personal information and would like to confirm whether or not we do, please send an email to firstname.lastname@example.org, indicating all email addresses which you may have given us.
However, we will seek your consent if we want to use your personal information for purposes other than those you have agreed to previously.
This Site may contain links to other sites, including those of our business partners. While we try to link only to sites that share our high standards and respect for privacy, please understand that we are not responsible for the content of, or the privacy practices employed by, other sites.
CVs are accessed by our consultants who seek to find you employment with third parties (“Third Parties”). Consultants are not permitted to disclose information outside our organisation or beyond the Third Party, as applicable. However, although Brevere Group deals only with reputable organisations, we cannot guarantee that all Employers and Third Parties will adhere to the limitations we impose on them.
Although we use all reasonable means to protect your personal information, Brevere Group is not responsible for any improper use of your personal information that is beyond our reasonable control.