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Where We Obtain Your Personal Data

We will obtain personal data relating to you:

  • Directly if you have:

    • applied for a Client vacancy through us

    • uploaded your CV through our website

    • asked us to provide any work-finding services to you

    • provided any such data on our posts or pages on social media sites such as Facebook, Twitter and Instagram

    • engaged with us through any networking activities or events

    • had any discussions with us about finding alternative employment

  • Indirectly from:

    • oonline professional networking sites such as LinkedIn

    • social networking sites such as Facebook or Twitter

    • job boards such as TotalJobs, CV Library, Career Structure, Indeed and LinkedIn

    • Clients who provide feedback about applications for employment or engagement which you have made, interviews which you have attended and assignments which you have carried out

    • Referees who provide information about your employment experience and their opinion as to your skills and aptitude

    • your employer’s website and other industry-related websites

    • business information directories

    • oonline industry databases such as the Construction Industry Training Board

    • where appropriate, third-party background checking services such as the Disclosure & Barring Service

Types of Personal Data We Hold

We will collect, store and process the following types of personal data about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and email addresses;

  • Your gender, date of birth, nationality and place of residence;

  • Your professional skills and experience;

  • Your qualifications, training and certifications;

  • Proof of your right to work in the United Kingdom such as copies of your passport and, where applicable, visa, residence permit or similar government documents;

  • Proof of your identity and address, such as copies of your driving licence, utility bills or similar documents;

  • Information about your current or most recent role, including your job title, department, reporting line, responsibilities, salary, benefits and notice period;

  • Your motivation and reasons for seeking new employment;

  • Any information within your CV or any application document which a Client may require you to complete;

  • Any background information which you provide to us during the course of your dealings with us;

  • Details of any Clients to whom you have been introduced by us;

  • Details of any interviews which you have attended and our Clients’ feedback on those interviews;

  • Details of any position which you take up with a Client, including your role, duties, remuneration, department and location;

  • If you provide any services on a freelance basis:

    • Details of any limited company through which you contract and the nature of your relationship with that company;

    • Information about the days and times which you have worked;

    • Your bank details, tax code and National Insurance Number; and

    • Information about any services which you have carried out, including any comments, feedback and issues relating to such services.

      We will also collect, store and use the following "special categories" of more sensitive personal data:

  • Information about your race or ethnicity;

  • Information about your health, including any medical condition, health and sickness records; and

  • Information about criminal convictions and offences.


How We Use Your Personal Data

We use your personal data to:

  • Assess and verify your potential suitability for employment with a Client;

  • Contact you in relation to any potential employment opportunities with a Client;

  • Introduce you to our Clients and potentially arrange for you to fill a Client vacancy;

  • Stay in regular contact with you to understand your current position, career aspirations and motivation for finding new employment;

  • Where applicable, make payments to you or arrange for any third-party company through which you may contract to make payments to you;

  • Contact you to ask for a referral;

  • Produce anonymised statistical data;

  • Carry out compliance checks to ensure that we have complied with our legal and contractual obligations;

  • Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime;

  • Conduct equal opportunities monitoring.


Our Lawful Basis for Processing Your Personal Data

We have determined that we have a legitimate interest to process your personal data where you are a Candidate on the basis that it is necessary for us to maintain a database of individuals who are (i) actively seeking new employment with a Client or (ii) potentially suitable for employment with a Client. By processing your personal data and contacting you from time to time, we are able to gain an understanding of your current role (where applicable), your skills and experience, and your career aspirations. Our processing of your personal data is therefore of benefit to:

  • You, as it assists us to identify new employment opportunities about which you might not otherwise been aware and to give general advice and guidance in support of your career development;

  • Our Clients, who rely on us to have access to suitable, pre-qualified candidates who can fill their requirements; and

  • Us, as we are a business which relies upon being able to introduce Candidates to our Clients

    In some circumstances, we may also process your data:

  • To perform a contract which we have with you. Irrespective of whether you are engaged for a temporary assignment through a third party limited company (where relevant), we will usually have a contract with you personally to provide work-finding services;

  • To comply with a legal obligation. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003 require us to hold certain data for at least one year from the date on which we last provide you with work-finding services.

    Our Lawful Basis for Processing Your Sensitive Personal Data

    We may also need to process sensitive (special) personal data relating to you. The type of sensitive personal data which we might process includes:

  • Information about any medical conditions or disability (i) where they are relevant to the type of work which you are proposing to carry out or (ii) where you have otherwise provided this in the course of dealing with us e.g. if you tell us the reason for a long term absence from work;

  • Information about any unspent criminal convictions and, where relevant to the type of role which you are carrying out, spent convictions, police warnings, cautions, etc and

  • Information about any trade union of which you are a member (but only insofar as it relates to an employment claim or pay and working conditions on a client site).

    We are acting as an employment agency and/or an employment business in our dealings with you. In accordance with Article 9 (2)(b) of the GDPR, this sensitive personal data is necessary in the field of employment. i.e. it is required for performing our obligations as an employment agency or employment business and is used solely for this purpose. Any sensitive personal data shall be held strictly in accordance with our policies on data retention and sensitive personal data.

    We may also process equal opportunities information relating to you. Although this may use sensitive personal data, it is anonymised and not therefore personal data within the meaning of the Data Protection Legislation.

    Parties with Whom We May Share Your Personal Data

    We may share your personal data for legitimate purposes with:

  • A Client where you have expressed an interest in being introduced to such Client or are being supplied to such Client on an assignment;

  • Any third-party which is engaged by the Client to assist them in the recruitment process including a managed service company, Recruitment Process Outsourcing provider or IT platform provider;

  • A Client-appointed compliance auditor (and/or the Client itself) for the purposes of demonstrating that we have complied with our legal and contractual obligations;

  • A third-party company through which you are contracting;

  • A third-party company to which you have specifically asked to be introduced or referred, such as an insurance company or intermediary (umbrella) company;

  • Background checking services such as the Disclosure & Barring Service;

  • Industry bodies such as the Construction Industry Training Board and any similar organisations which are relevant to the market sector in which you work;

  • Suppliers who in some cases may use their own subcontractors and sub-processors;

  • Our bankers and recruitment finance providers;

  • Governmental departments and agencies where we are permitted or required by law to do so.

We will share sensitive personal data relating to you with our Clients if there is a legitimate reason to do so. For example, we will share information about any medical condition which you have if it is relevant for health & safety purposes. We will share information about any convictions which you disclose as we are under a legal obligation to notify our Client of information which is relevant to your suitability to carry out an assignment.

We may also share your personal data with Clients on an anonymised basis where we have agreed to provide general statistical information to such Clients.

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