General Data Protection Regulations (GDPR)
Recruitment Direct Leominster Ltd is a recruitment business which provides work-finding services to it’s clients and work-seekers. Recruitment Direct Leominster Ltd must process personal data (including sensitive personal data) so that it can provide these services – in doing so, Recruitment Direct Leominster Ltd acts as a Data Controller.
Recruitment Direct Leominster Ltd are a registered Data Controller with the Information Commissioners Office, registration number: Z135720X
In submitting your CV to Recruitment Direct Leominster Ltd via email, our website (general submission or vacancy application) or to a Recruitment Direct Leominster Ltd vacancy via a jobs board, you imply consent for Recruitment Direct Leominster Ltd to process your personal data for the purposes of considering your suitability for vacancies and provision of work-finding services.
Recruitment Direct Leominster Ltd will contact you to arrange an appointment for a registration interview. You will then be added to our register in order to be considered for current and future vacancies. Upon registration you will have the opportunity to formally consent to our processing your personal data (detailed in the privacy statement below).
CVs of unregistered candidates will be retained for one calendar year, after which period they will be erased.
We do not submit CVs of unregistered candidates to clients without the candidate’s prior consent, neither do we process information not directly obtained from the data subject (e.g. take CVs directly from jobs boards). Personal data, other than the data subject’s name is not provided to clients without consent of said data subject.
Recruitment Direct Leominster Ltd receive personal data in the following ways:
- Registration form
- External job boards
Recruitment Direct Leominster Ltd must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you, we will only use your personal data in accordance with the terms of the following statement:
- Collection and Use of Personal Data
What is Personal Data?
Any data that identifies a living individual.
What Personal Data is processed by Recruitment Direct Leominster Ltd:
Name, Contact Details, Date of Birth (for National Minimum Wage/National Living Wage categorisation plus if under 22 for health & safety), Nationality (for Right to Work), Bank Details* (*once undertaking a temporary assignment, for payroll and pensions).
What is Sensitive Personal Data?
Ethnic origin, political opinion, religious belief, trade union membership, medical, physical or mental health condition, sexual preference or orientation, criminal record, genetic or biometric data.
What Sensitive Personal Data is processed by Recruitment Direct Leominster Ltd:
Medical (suitability and health & safety), Criminal Record (suitability).
Purpose of Processing and Legal Basis
Recruitment Direct Leominster Ltd will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. The legal basis we rely upon to offer these services to you are:
- Legitimate interest
- Legal obligation
- Contractual obligation (performance of a contract)
Where Recruitment Direct Leominster Ltd has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
- Providing candidates to Clients to undertake temporary assignments on behalf of Recruitment Direct Leominster Ltd
- Providing candidates to Clients to fulfil contract or permanent vacancies with the Client
In order to provide these services, it is necessary to obtain candidates contact details, check identity, right to work, qualifications and suitability for the role, process pay and statutory deductions.
Recipient/s of Data
If you accept and undertake a temporary assignment, Recruitment Direct Leominster Ltd, under the legal basis of performing a contract, will process your personal data with the following recipients:
- Outsourced Payroll provider
- Pension Scheme provider
Recruitment Direct Leominster Ltd has Information Sharing Agreements with these organisations.
If you accept the offer of a permanent position or fixed term contract Recruitment Direct Leominster Ltd will, with your consent, pass your personal data (contact details) to the client to enable them to contact you directly.
Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the relevant personal data, if you do not the consequences of failure to provide the data are:
- Recruitment Direct Leominster Ltd will not be able to submit you to Clients for temporary assignments/contracts or permanent vacancies
- If you accept and undertake a temporary assignment without provide bank details, Recruitment Direct Leominster Ltd will not be able to pay you for hours worked
2. Data Retention
Recruitment Direct Leominster Ltd will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.
Work seeker records will be retained for as long as the work seeker requires work finding services, then the Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year* from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services (during which time the candidate will be able to re-open their records without having to attend a registration interview).
Terms of Engagement for Temporary Workers are required to be retained for 6 years.
(*this will be one calendar year from the calendar year created or last provided with work finding services, archive audit and erasure will be in January each year).
We must also keep your payroll records including, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently 3 years for payroll and 6 years for pensions.
Where Recruitment Direct Leominster Ltd has obtained your consent to process your personal and sensitive personal data we will do so in line with our retention policy. Upon expiry of that period Recruitment Direct Leominster Ltd will seek further consent from you. Where consent is not granted Recruitment Direct Leominster Ltd will cease to process your personal data and sensitive personal data (after which time the candidate will need to re-register in the event they wish to be considered for suitable vacancies) (see Erasure/ Withdrawal of Consent section below).
To enable Recruitment Direct Leominster Ltd to ensure data processed is correct, updates of the active register and candidate details are scheduled at a maximum of 6 monthly intervals.
- Your Rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data Recruitment Direct Leominster Ltd holds;
- The right of access to the personal data Recruitment Direct Leominster Ltd holds;
- The right to rectification of your personal data;
- The right to erasure of your personal data in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on a public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
Where you have consented to Recruitment Direct Leominster Ltd processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting Claire Plowman, Director/Data Protection Officer.
- Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Claire Plowman, Director/Data Protection Officer on 01568 615262 or firstname.lastname@example.org
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.
- Erasure/Withdrawal of Consent
Please note that erasure and withdrawal of consent are not absolute rights if the data is processed under performance of a contract or legal obligation (for example payroll records).
In the event that an assignment has been terminated due to poor conduct for example, Recruitment Direct Leominster Ltd will retain the name of said candidate to ensure said candidate is not resubmitted to that client.
In the event of erasure, if the candidate has undertaken temporary assignments, Recruitment Direct Leominster Ltd will no longer be able to provide references.
In the event of erasure and withdrawal of consent, Recruitment Direct Leominster Ltd is not responsible if the data subject then re-submits their CV to Recruitment Direct Leominster Ltd in order to use their work-finding services, the applicant will then have to repeat the full registration process.
Please contact Claire Plowman, Director/Data Protection Officer on 01568 615262 or email@example.com for access to the documents stated below:
- Data Protection Policy
- Withdrawal of Consent Form
- Subject Access Request Form
- Subject Access Request Policy
If you do not wish to be contacted by Recruitment Direct please email firstname.lastname@example.org
Further information on GDPR: