PRIVACY NOTICE – RIVERVIEW RECRUITMENT LIMITED

 

INTRODUCTION

This Privacy Notice sets out the basis on which we use personal data in the course of our

business activities.

As a business which relies upon having access to information about Candidates to meet our

Clients’ requirements, data is essential to our business. Our systems and processes are

designed to ensure that we can provide the best possible service to our clients while

operating within the law at all times and protecting individuals’ data privacy rights.

We reserve the right to update this Privacy Notice from time to time. Where appropriate,

we shall contact you to notify you of any material changes to the Privacy Notice. You should

also refer to our website periodically so that you may access and view our updated Privacy

Notice. This will ensure that you understand (i) how we are using your personal data and (ii)

your legal rights around our usage of such personal data.

For an explanation of the definitions which are used in this Privacy Notice, please refer to

the section at the end of the document.

 

WHO SHOULD READ THIS PRIVACY NOTICE?

This Privacy Notice applies to any living, identifiable individuals about whom we may

process personal data in the course of our business activities.

You should read this Privacy Notice if you are a:

Candidate

Client Contact

Referee

Supplier Contact

 

Please note that, in some cases, you will fall into more than one of the above categories.

CANDIDATES

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

o uploaded your CV through our website

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

o provided any such data on our posts or pages on social media sites such as

  Facebook, Twitter and Instagram

o engaged with us through any networking activities or events

o had any discussions with us about finding alternative employment

 

Indirectly from:

    o online professional networking sites such as LinkedIn

    o social networking sites such as Facebook or Twitter

    o job boards such as CV Library and Total Jobs

    o 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

    o Referees who provide information about your employment experience and

        their opinion as to your skills and aptitude

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

    o business information directories

    o online industry databases such as the RICS, BIFM

    o 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:

 

o Details of any limited company through which you contract and the nature of

  your relationship with that company;

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

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

o 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:

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

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

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

  ï Stay in regular contact with you to understand your current position, career

      aspirations and motivation for finding new employment;

  ï Where applicable, make payments to you or arrange for any third-party company

      through which you may contract to make payments to you;

  ï Contact you to ask for a referral;

  ï Produce anonymised statistical data;

  ï Comply with our legal obligations, defend or bring any legal proceedings and prevent

      fraud or any other crime;

  ï 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

 

If you are a Candidate, we may also need to process sensitive (special) personal data

relating to you. The type of sensitive personal data which we might process includes (i)

information about any medical conditions or disability insofar as they are relevant to the

type of work which you are proposing to carry out (ii) information about any unspent

criminal convictions and, where relevant to the type of role which you are carrying out,

spent convictions, police warnings etc and (iii) 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. This shall be

anonymised and it is not therefore personal data within the meaning of the Data Protection

Legislation.

Parties with Whom We Share Your Personal Data

When arranging freelance recruitment services, we act as the agent of Quba Solutions

Limited (Registered in England & Wales No. 07907578). Quba Solutions Limited is the party

with which you will contract and we therefore share your personal data with Quba

Solutions Limited for the purposes of arranging the provision of such freelance recruitment

services.

We may also 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 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 financiers;

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.

 

CLIENT CONTACTS

Where We Obtain Your Personal Data

We obtain personal data relating to you:

Directly in the course of dealing with you as a representative of the Client

Indirectly from:

    o online professional networking sites such as LinkedIn

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

    o business information directories

    o other individuals within your organisation in the course of us providing

        services to the Client.

 

Types of Personal Data We Hold

We collect, store, and use the following categories of personal data about you:

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

email addresses;

Your job title and position within the Client organisation; and

Any background information relating to your personal circumstances, your work

history and the role which you perform within the Client which you may provide to

us in the course of your dealings with us.

We do not collect, store or use any “special categories” of sensitive personal information if

you are a Client Contact.

 

How We Use Your Personal Data

We use your personal data to:

Contact you to obtain information about our Client’s requirements;

Liaise with you so that we may effectively perform the services to our Client;

Contact you to inform you of a Candidate’s availability or interest in a job role;

Obtain a reference for a Candidate;

Contact you for invoicing and credit control purposes;

Provide you with statistical information about your industry sector;

Comply with our legal obligations, defend or bring any legal proceedings and prevent

fraud or any other crime.

 

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 Client Contact on the basis that we need to be able to contact and interact

with the individuals who are employed or engaged by our Clients. This will allow us to

effectively provide services to them, better understand their requirements and generate

revenue for our business. We do not use your data in any way which could reasonably be

considered to be prejudicial to your interests.

 

Parties with Whom We Share Your Personal Data

We may share very limited data relating to you with a Candidate where such sharing is

strictly required for the recruitment process e.g. so that the Candidate may contact you

directly.

When arranging freelance recruitment services, we act as the agent of Quba Solutions

Limited (Registered in England & Wales No. 07907578). Quba Solutions Limited is the party

with which our Client contracts and we will therefore share your personal data with Quba

Solutions Limited for the purposes of arranging the provision of freelance recruitment

services.

We will also share your personal data with Suppliers for legitimate business purposes.

SUPPLIER CONTACTS

Where We Obtain Your Personal Data

We obtain personal data relating to you:

Directly in the course of our dealings with you as a representative of the Supplier;

and

Indirectly from:

    o online professional networking sites such as LinkedIn

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

    o business information directories

    o other individuals within your organisation in the course of the Supplier

        providing services to us.

Types of Personal Data We Hold

We will collect, store, and use the following categories of personal information about you:

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

email addresses;

Your job title and position within the Supplier organisation; and

Any background information relating to the role which you perform within the

Supplier which you may provide to us in the course of your dealings with us.

  

We do not collect, store or use any “special categories” of sensitive personal information if

you are a Supplier Contact.

 

How We Use Your Personal Data

We use your personal data to:

Liaise with you in respect of services which are being provided by the Supplier;

Contact you in relation to billing matters;

Comply with our legal obligations, defend or bring any legal proceedings and prevent

fraud or any other crime.

 

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 Supplier Contact, on the basis that we need to be able to contact and

interact with the individuals who are employed or engaged by our Suppliers. This will allow

us to ensure that our Suppliers provide us with the best possible service which, in turn, is of

direct benefit to both our Candidates and our Clients. We do not use your data in any way

which could reasonably be considered to be prejudicial to your interests.

 

Parties with Whom We Share Your Personal Data

We will share your personal data with other Suppliers for legitimate business purposes.

REFEREES

Where We Obtain Your Personal Data

We obtain personal data relating to you:

ï Directly from you in the course of any communications between us; or

ï Indirectly from:

o the Candidate who has nominated you as his or her Referee

o online professional networking sites such as LinkedIn

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

 

Types of Personal Data We Hold

We collect, store, and use the following categories of personal data about you:

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

email addresses;

Your job title and position within your employer; and

Any background information which you may provide to us in the course of your

dealings with us.

We do not collect, store or use any “special categories” of sensitive personal information if

you are a Referee.

 

How We Use Your Personal Data

We use your personal data to:

Contact you to obtain a reference on a Candidate;

Provide a copy of the reference to our Client;

Comply with our legal obligations, defend or bring any legal proceedings and prevent

fraud or any other crime.

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 Referee, on the basis that we are generally required to obtain references

to comply with our contractual obligations to third parties and, in some instances, we are

under a legal obligation to do so. It is therefore necessary and reasonable for us to process

personal data relating to you strictly for compliance with these obligations.

Parties with Whom We Share Your Personal Data

We will share the details of any reference which you give with our Clients. We will usually

provide your name, job title and employer name when doing so. In some circumstances and

only when you have agreed to such disclosure, we will provide your contact details so that

our Client may verify the reference or ask for further information. We will also share your

personal data with Suppliers for legitimate business purposes.

 

WHERE WE PROCESS PERSONAL DATA

Your personal data is held and processed by us in the United Kingdom.

We have put in place appropriate safeguards to ensure that your data is only transferred to

jurisdictions with enforceable data subject rights and effective legal remedies in respect of

data privacy breaches. We will therefore only transfer your personal data to jurisdictions

outside of the EEA where:

ï

There are binding corporate rules in place regarding the transfer of such data within

the Group, in accordance with Article 47 of the GDPR. This means that the data

transfer is between group companies and those group companies have agreed to

share that data in accordance with the rules specified by the European Commission.

The European Commission has made an adequacy decision in respect of such

jurisdiction. This means that the European Commission has pre-approved the data

privacy regime in the relevant non-EEA country. At present, the European

Commission-approved jurisdictions are Andorra, Argentina, Canada (commercial

organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand,

Switzerland, Uruguay and the US (limited to the Privacy Shield framework).

The transfer of data is subject to the model contractual clauses adopted by the

European Commission. This means that we have a data-sharing agreement in place

which complies with the requirements set out by the European Commission; or

You have expressly given informed consent to the transfer of such data. This means

that you have not only agreed to the transfer but have done so in the knowledge that

your data may be transferred to a jurisdiction which does not give you the same

degree of protection as you have within the EEA.

 

OUR WEBSITE

If you interact with our website at http://www.riverview.careers/, we may record

your IP address and process statistical information relating to your usage of the website. We

use cookies for this purpose and, for information on the cookies which we use, you should

refer to our Cookie Policy on our website.

AUTOMATED DECISION MAKING

Automated decision-making takes place when an electronic system uses personal

information to make a decision without human intervention.

All decisions which are made in the course of our business processes involve human

intervention. We do not make any decisions using automated means.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal information

from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal information to those employees, agents,

contractors and other third parties who have a business need to know. They will only

process your personal information on our instructions and they are subject to a duty of

confidentiality. Details of these measures may be obtained from the Data Protection

Manager.

We have put in place procedures to deal with any suspected data security breach and will

notify you and any applicable regulator of a suspected breach where we are legally required

to do so.

DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes

we collected it for, including for the purposes of satisfying any legal, accounting, or

reporting requirements. To determine the appropriate retention period for personal data,

we consider the amount, nature, and sensitivity of the personal data, the potential risk of

harm from unauthorised use or disclosure of your personal data, the purposes for which we

process your personal data and whether we can achieve those purposes through other

means, and the applicable legal requirements.

Our standard data retention period is three years from the last date on which we are in

actual contact with you i.e. where we actually speak with you or exchange correspondence.

After this time, we will usually delete your personal data from our records.

Where we are required to keep any information (i) for auditing or compliance purposes (ii)

to comply with our contractual obligations to third parties or (iii) in respect of any potential

or actual legal proceedings, we shall keep your data for as long as is strictly necessary for

these purposes, which is typically for seven years in respect of audit data which we may be

required to produce for HRMC and/or to prove compliance with our contractual and legal

obligations.

In some circumstances we may completely anonymise your personal information so that it

can no longer be associated with you, in which case we may use such information without

further notice to you.

RIGHTS OF ACCESS, CORRECTION, ERASURE & RESTRICTION

Your duty to inform us of changes. It is important that the personal information we hold

about you is accurate and current. Please keep us informed if your personal information

changes during your working relationship with us.

Your rights in connection with personal information. Under certain circumstances, you

have the right to:

Request access to your personal information (a Subject Access Request). This

enables you to receive a copy of the personal information we hold about you and to

check that we are lawfully processing it. You will not usually have to pay a fee to

access your personal information but we may charge a reasonable fee if your

request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to

comply with the request in such circumstances.

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 the personal data is no longer necessary in

relation to the purpose for which it was originally collected/processed or you have

objected to the processing and there is no overriding legitimate interest for

continuing the processing.

Object to processing of your personal information where we are relying on a

legitimate interest and you object on “grounds relating to your particular situation.”

Request the restriction of processing of your personal information. This enables you

to ask us to block or suppress the processing of personal information about you, for

example if you want us to establish its accuracy or the reason for processing it or if

you have also objected to the processing as above.

Request the transfer of your personal information to another party when the

processing is based on consent and carried out by automated means. This right is

not usually applicable to any data processing carried out by us.

If you want to exercise any of the above rights, please contact the Data Protection Manager

in writing. We will consider your request and confirm the actions which we have taken in

response to such request.

We may need to request specific information from you to help us confirm your identity and

ensure your right to access the information (or to exercise any of your other rights). This is

an appropriate security measure to ensure that personal information is not disclosed to any

person who has no right to receive it.

In the limited circumstances where you may have provided your consent to the collection,

processing and transfer of your personal information for a specific purpose, you have the

right to withdraw your consent for that specific processing at any time. To withdraw your

consent, please contact the Data Protection Manager. Once we have received notification

that you have withdrawn your consent, we will no longer process your information for the

purpose or purposes you originally agreed to, unless we have another legitimate basis for

doing so in law. We will confirm the actions which we have taken in respect of any such

request.

 

If you are unhappy with any aspect of the manner in which we have processed your

personal data or dealt with your decision to exercise any of the rights set out in this section,

you have the right to complain to the Information Commissioners Office in the United

Kingdom. Their details are:

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9

5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745

Email: casework@ico.org.uk

DEFINITIONS

This Privacy Notice uses the following defined terms:

Candidate means a person who is recorded in our records as seeking or potentially suitable

for an engagement with a Client. This includes individuals who are not actively seeking a

new role but who are in contact with us about potential opportunities which may be of

interest from time to time.

Client means a business which has engaged us to provide services or which we have

identified as a business for which we wish to perform services.

Client Contact means a person who is employed or engaged by a Client and with whom we

may liaise in respect of any services which we are providing or wish to provide to the Client.

In some cases, the Client Contact and the Client may be the same person e.g. where a Client

is a sole trader.

Data Protection Legislation means (i) the Data Protection Act 2018, the General Data

Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and

secondary legislation, as amended or updated from time to time, in the UK and then (ii) any

successor legislation to the GDPR or the Data Protection Act 2018.

Referee means a person who has provided to us a written or verbal opinion in respect of

the work history, skills, competency and/or experience of a Candidate;

Supplier means a business which provides services to us and which may process personal

data relating to any Candidate, Client Contact or Supplier Contact in the course of

performing such services including our:

Professional advisers including accountants, tax advisors and lawyers;

Insurers;

IT services providers and software providers; and

Independent consultants and subcontractors

Supplier Contact means a person who is employed or engaged by a Supplier and with

whom we may liaise from time to time in respect of the services which are provided by that

Supplier.

 

CONTACTING US

We are Riverview Recruitment Limited (Registered in England & Wales No. 11282456). Our

registered office is at 60 Birchwood avenue, Wallington SM6 7EN.

 

Alternatively, you may telephone us on 0203 667 3111 or email us at info@riverview.careers

 

© 2019 by Riverview Recruitment. 

Tel: +44 (0)20 3667 3111