The Company (Watsons Recruitment Ltd) acts as both a recruitment agency and recruitment business, which provides related services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.
You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. In the case of a client, you may provide your personal data to enable us to fulfil our service obligations to you. The Company 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.
1. Collection and use of personal data
a. Purpose of processing and legal basis
The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with recruitment services or employment, either as a work-seeker or as a client or an employee of The Company. Should you be a work-seeker, these services could include for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients. Should you be a client, the services could include; passing your details to work-seekers for the purpose of arranging interviews, contacting you about our range of recruitment services, updating your information on our databases, managing our relationship and the issuing of invoices and other related documents.
In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
The legal bases we rely upon to offer these services to you are:
- Your consent
- Where we have a legitimate interest
- To comply with a legal obligation that we have
- To fulfil a contractual obligation that we have with you
b. Legitimate interest
This is where the Company has a legitimate reason to process your data, provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests will typically be as follows:
- Managing and updating records kept on our databases.
- Contacting you to discuss business services that we provide, including work finding and/or recruitment services.
- Providing work-finding services, including sending your information to our clients, where you have demonstrated an interest in doing that particular type of work but not expressly consented to the passing on of your cv;
- Providing you with marketing information about other associated services that we offer.
- To enable you as a supplier of goods and/or services to The Company.
- Processing financial data where applicable.
- Correct management of employee records.
- Passing your information to government bodies as required by law.
c. Recipient/s of data
- The Company will process your personal data and/or sensitive personal data with the following recipients:
- Clients that we introduce you to or supply our recruitment services to.
- Candidates/work-seekers whom may engage with you during the recruitment process.
- Any prospective new employers that we obtain or provide references to.
- Other recruitment agencies in instances where we are working in a tiered supply chain.
- Social networks.
- Our Information Technology and CRM providers who host our databases, websites and any online communication software such as email and/or file sharing.
- Any public information sources, trade associations or third party organisations that we may use to carry out suitability checks.
- Any third party individuals or organisations that are approved to perform relevant services on behalf of the Company, such as; payroll bureaus, accountants, financial services providers.
- Government, law enforcement agencies and other regulators.
- Trade unions.
- Any of our group companies.
- Any other organisations where you have requested that we share your data.
d. Statutory/contractual requirement
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. Under our statutory obligations including
the Conduct of Employment Agencies and Employment Businesses Regulations 2003,
if we are unable to obtain the required level of personal data then we may be
unable to provide you with work-finding or recruitment services.
2. Data retention
The Conduct of Employment Agencies and Employment Businesses Regulations
2003, require us to keep work-seeker records for a minimum of one year from (a)
the date of their creation or (b) after the date on which we last provided you
with our services.
The Company will retain your personal data for a maximum of three years
from the date of our last communication, on the legal bases of Legitimate
Interest. Different laws may also require us to keep different data for
different periods of time. After these time periods have elapsed, your personal
data will be erased from all electronic databases and any physical hard copies
destroyed. Should you wish for us to remove your personal data from our records
sooner than stated above, you may request to exercise your right to object to
the processing of your personal data by either; emailing us on email@example.com or in writing to; Data Management, Watsons
Recruitment Ltd, 15 Stowe Walk, Daventry, NN11 8AY. We will aim to respond to
your request within 7 working days.
Should you work through The Company as a Temporary Agency Worker or be
directly employed, we must also keep your payroll records, holiday pay, sick
pay and pension auto-enrolment records for as long as is legally required by
HMRC. This includes associated national minimum wage, social security and tax
legislation and therefore this may require us to retain your records for longer
than stated above, due to requirements by law.
3. Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you;
- The right of access to the personal data the Company processes on you;
- 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 the Company processing your personal data, you have the right to withdraw that consent at any time by contacting us either by the following email address: firstname.lastname@example.org, or by writing to; Data Management, Watsons Recruitment Ltd, 15 Stowe Walk, Daventry NN11 8AY.
There may be circumstances where the Company will still need to process
your data for legal or official reasons. We will inform you if this is the
case. Where this is the case, we will restrict the data to only what is
necessary for the purpose of meeting those specific reasons.
If you believe that any of your data that the Company processes is
incorrect or incomplete, please contact us using the details above and we will
take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to
restrict the type or amount of data we process for you, access your personal
data or exercise any of the other rights listed above.
4. Automated decision-making
The Company does not utilise any automated decision-making processes.
5. Complaints or queries
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.
6. Data submitted