S.TWO Privacy Notice - April 2019
We care about your information.
S.TWO ("the Company") is a data controller and data processor for the purposes of data protection legislation. Relevant, authorised members of our staff will have access to the information. We ask you to share information with us so that we can provide you with work-finding and related services.
This document tells you what you can expect from us and how we will protect your rights. It applies to information we collect about agency workers, staff members and individuals who work at the companies we do business with.
If you wish to exercise any of your rights or should you have any questions or concerns about S.TWO and its personal data policies or practices,
please contact: email@example.com
Why do we process your information?
We process information about you, known as 'personal data', to enable us to carry out our business as an employment agency for the purposes of permanent recruitment services and as an employment business for the purposes of temporary recruitment services.
By law, we have obligations to ensure that the candidates we place into vacancies are suitable for those positions and that the vacancies are suitable for those candidates. We have a duty of care to look after the best interests of our customers and to do that we need to collect and process relevant information.
Who will we share information with?
Information shared with client organisations - In order for our client organisations to consider workers for opportunities within their businesses, we need to share worker information with them. Information shared with workers - In order to perform our recruitment services (such as arranging interviews, for example) we often need to share client contact information (such as name, job title and contact details) with workers.
Information shared with third parties - In order to perform our recruitment services and maintain data security, we may need to share information with third parties for legitimate business reasons for example for payroll purposes.
Auditors & Inspectors - From time to time we may be audited by third parties to ensure that we are operating a legally compliant and ethical business. These third parties may include:
- Government regulatory and enforcement audits
- Independent social compliance audits
- Quality assurance audits
- Client and/or supplier audits
Government agencies and law enforcement bodies - we may also provide your information to other third parties such as but not limited to regulators and law enforcement bodies, where we are required to do so by law, where necessary for the purpose of preventing and detecting fraud, other criminal offences and/or to ensure network and information security.
Other - If we would like to share your data with anyone not covered in this privacy notice (such as sharing testimonials with potential customers, for example), we will only do this where we have a legitimate reason to do so and where required will ask for your specific consent to do so.
We collect personal data that you provide to us when applying for a role or registering for our job-finding services to comply with our legal obligations and those of our clients regarding your right to work and any necessary qualifications for roles. We may also process your personal data for this purpose where we consider it necessary to perform the contract with you, or otherwise with your consent.
We undertake the following with your consent:
Marketing - where legally permitted to do so where you have provided us with your contact details and have agreed to be contacted for marketing purposes, we may contact you by telephone, email or by post for marketing purposes relating to our services, our website, and/or to research opinion on proposed business developments. Your agreement to the use of your personal data for these purposes is optional and If you fail to provide your agreement, your use of our work-finding services will not be affected.
International Transfers of your Personal Data
We do not transfer personal data out of the EEA.
Security and Confidentiality
We employ appropriate security measures to help protect your personal data and guard against access by unauthorised persons. Information storage is on a secure database in a secure environment. The information is encrypted wherever possible and we undergo periodic reviews of our security policies and procedures to ensure that our systems are secure and protected. However, the transmission of information via the Internet is not completely secure so we cannot guarantee the security of your information when it is transmitted to our website or from third party websites such as job boards.
We acknowledge that the information you provide may be confidential. We do not sell, rent, distribute or otherwise make personal data commercially available to any third party, but we may share information with our clients, service providers and for the purposes set out in this Privacy Notice. We will keep your information confidential and protect it in accordance with our Privacy Notice and all applicable laws.
What are your rights?
All individuals have the following rights regarding their personal data:
- The right to be informed - You have the right to know what information we hold about you, what we are using it for, who we are sharing it with, how long we are keeping it, and on what basis we are processing the data. While we always prefer to process data based on your explicit consent, as a recruitment organisation we also have a 'legitimate interest' in processing your data to ensure we are matching you to suitable vacancies. There are also times when we have to process your information because we are required to by law.
- The right of access - If you would like to see the records we hold on file for you, please contact firstname.lastname@example.org All requests must be made in writing and will be dealt with within 30 days.
- The right to rectification - If you believe we are holding incorrect information, you can ask us to correct it.
- The right to erasure - You can ask us to remove your information from our records. As long as there is no legal requirement for us to keep them (for example, HMRC require us to keep payroll records for up to 7 years), we will remove your details. This will mean that we won't be able to contact you with any work opportunities in future.
- The right to restrict processing - Instead of asking to be removed, you can ask us to stop processing it - so you can ask us to stop contacting you about work opportunities, for example.
- The right to data portability - If you want to take your data to another organisation, please contact email@example.com
- The right to object - You have the right to object to your data being processed on the basis of legitimate interests, direct marketing, and processing for statistical purposes. We will stop processing your information immediately unless there are legal reasons for us not to do so.
- The right not to be subject to automated decision-making (including profiling) - You have the right to object to automated decision-making. Results for our psychometric testing are generated automatically. However, if you wish to challenge the result you have achieved, the result can be checked manually on request.
What information do we collect? How do we use it? How long do we keep it?
How do we collect your personal data?
- When you respond to an advert on a job board or other website;
- When you directly contact our business;
- When you complete an application form and/or submit a CV;
- When you speak to our staff by telephone;
- When another agency and/or organisation passes your details to us.
This privacy notice has been divided into sections, so that you can read the information relevant to you. Each section tells you what information we collect, how we use it, and how long we will keep it for. These sections are:
- Candidates / workers
- Individuals who work at the companies we do business with
CANDIDATES / WORKERS (including but not limited to: Applicants, Agency Workers, Temporary Employees, Apprentices, Graduates)
This section refers to individuals we supply to work with our client companies.
What information do we collect?
We collect personal data from you in order to fulfil our contract with you, to comply with our legal obligations and where it is in our legitimate interests in order to provide you with work seeking services and to supply our clients with labour. Where we have not entered in to a contract, we may also collect personal data if it is necessary and within our legitimate business interests in order to deal with your enquiries, requests or communication.
This will include:
- Your name and contact details.
- Your right to work status (and to take copies of your passport/other allowable documents).
- Your work history, skills, experience, education and qualifications (where relevant).
- Details about the type of work you are looking for.
- Your next of kin.
- Whether you require any reasonable adjustments in the recruitment process.
- Questions about your work seeking activity, to help us make sure we are protecting your welfare and your rights.
- Your national insurance number and bank details in order to pay you for any work you do.
- Information collected via cookies or similar technology.
- Information from social media when you interact with us via social media.
- Additional information you may provide voluntarily and/or which we may ask you for to better understand your interests and preferences.
- Reference details.
- Whether you have any unspent criminal convictions.
- Information on your physical or mental health and wellbeing relevant to the type of work you are applying for and whether you require any reasonable adjustments to undertake any roles.
For some roles, we may use assessments as part of the recruitment process such as literacy, numeracy, or psychometric tests, and these results will be held on file.
We may also collect sensitive data about you that you choose to provide voluntarily such as but not limited to information regarding gender, racial/ethnic origin, criminal allegations/offences, trade union membership.
How do we use it?
The information we collect will only be used for the purposes of progressing your application for work, or to fulfil legal or regulatory requirements if necessary. The information we ask for helps us to assess your suitability for work and enables us to provide a work seeking service by:
- Responding to your queries.
- Providing you with work seeking services and information.
- Sharing your information between our offices for payroll and administrative purposes.
- Communicating assignment information.
- Sharing information with our clients for work seeking and on-boarding purposes.
- Confirming hours worked for payroll purposes.
- Ensuring network and information security.
We will only collect and use your personal data when (1) it is necessary for our legitimate business interests and in accordance with applicable law and your legal rights and/or; (2) where you have provided consent and/or; (3) where this is necessary to comply with legal obligations.
You don't have to provide the information we ask for, but it might affect our ability to provide you with work if you don't.
How long do we keep it?
We keep your information in line with our retention policy as follows:
Candidate data: Is reviewed on an ongoing basis. We set to review your data with you at minimum every 18 months to see where you are on your journey back to work, having returned to work and to ensure our service is still relevant to you and that your data is still accurate. If we have had no communication with you following five years we will delete your records.
Client contact details: If we have had no communication with you following five years we will delete your records.
Third parties are individual members of staff at the supplier, support, client and other organisations we work with to perform the legitimate activities of our business.
What information do we collect?
We collect personal data in order to comply with our legal obligations and where it is in our legitimate interests as an employer/labour provider to do so.
Individuals within the companies we work with are also entitled to have their personal data protected.
We will only share information where it is allowed by law and relevant to our legitimate business activities, such as providing name, job title and contact details when arranging an interview.
We may also share professional information that is already in the public domain (such as company website pages, LinkedIn profiles, and similar media).
How do we use it?
The information we ask for will only be used in connection with the legitimate activities of our business.
How long do we keep it?
We keep the information for either the minimum period we are required to keep it by law, or for as long as you give us consent to keep the information, whichever is longer.
We will retain contact details for individuals within client organisations while the organisation remains a current or prospective client organisation.
Individuals within the organisations we work with have the same rights as any other individual (including the right to be forgotten). Anyone wishing to exercise their rights under data protection legislation should contact firstname.lastname@example.org
Changes and updates to the Privacy Notice
By engaging with us and using our website and services, you agree to the terms and conditions contained in this Privacy Notice and/or any other agreement that we might have with you. If you do not agree to any of these terms and conditions, you should not use our website or any services provided by S.TWO. You agree that any dispute over privacy or the terms contained in this Privacy Notice, or any other agreement we have with you, will be governed by the laws of the United Kingdom.
As our business changes from time to time, this Privacy Notice is expected to change as well. We reserve the right to amend the Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice on our website. We may e-mail periodic reminders of our notices and terms and conditions and will e-mail customers of material changes thereto, but you should check our website frequently to see the current Privacy Notice that is in effect and any changes that may have been made to it. The provisions contained herein supersede all previous notices or statements regarding our privacy practices and the terms and conditions that govern the use of the website.
Questions, concerns or complaints
Please contact us at the address below:
S.TWO, Building 6, Suite 7a,
Croxley Park, Watford, WD18 8YH;
Please note S.TWO is the trading name of S.TWO Consult Ltd.