Privacy Policy

Company Name:   Situations Recruitment Agency Ltd (“the Company”)

Date:                   22.03.18


This privacy statement sets out below:-
 The Company is committed to protecting and respecting your privacy in accordance with the Data Protection (Bailiwick of Guernsey) Law 2017 and the General Data Protection Regulation. This statement and the documents referred to in it set out the basis on which any personal information we collect from you, or obtain from other sources, will be processed by us in the course of providing you with employment/recruitment services and/or information. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

  1. The types of information the Company may collect
  2. How the Company collects your Personal Information
  3. How the Company uses Personal Information.
  4. Grounds for using your Personal Information
  5. How we use Special Category Data
  6. Data Sharing
  7. Data Security Procedures
  8. Your rights
  9. Data Retention
  10. Changes to this Privacy Policy
  11. Complaints or Queries

 

  1. The types of information the Company may collect

 

We collect personal information on candidates and contractors to whom we provide services, as well as contacts at employers in the course of providing employment/recruitment services and/or information. “Personal Information” is any information that can be used to identify you or that we can link to you as an individual and may include:

  • Personal contact details such as: name, address, telephone numbers and email addresses
  • Date of birth
  • Gender
  • Marital status and dependents
  • Next of kin and emergency contact information
  • Social security number
  • Bank account details, payroll records and tax status information
  • Salary, annual leave, pension and benefits information
  • Start date
  • Location of employment or workplace
  • Photo identification, e.g. passport or driving licence
  • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
  • Certificates of any Academic and/or any Professional Qualifications obtained
  • Employment records (including job titles, work history, working hours, training records and other professional memberships).
  • Remuneration history.
  • Performance information
  • Disciplinary and grievance information
  • Information about your use of information and communications systems
  • Photographs
  • Information we collect automatically through cookies and similar technologies through our online services (please see our Website Policy for more details)

We may also collect, store and use the following “Special Categories of Data”:

  • Information about your health, including any medical condition, health and sickness records
  • Information about criminal convictions and offences

 

  1. How the Company collects your Personal Information

 

  • Candidates

 

We request information from you on our online registration forms.  Here you provide your name and contact information and you can also provide information regarding the type of work you are seeking, your CV, and your skills, qualifications and experience.  Depending on the role, our Consultants may contact you to request further information.

 

  • Contractors

 

We collect personal information about employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from another employment agency or referees. We may sometimes collect additional information from third parties including former employers, credit reference agencies or third parties who undertake background checks. We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

 

  • Contacts at employers

 

We collect personal information about our contacts at employers through the process of undertaking candidate searches on their behalf, either directly from the individuals themselves or sometimes from their colleagues to enable us to keep in touch.

 

  • Information we may collect from third party sources

 

In addition to the above for all categories we may receive information about you from other sources, including third parties and publicly available information that help us: update, expand, and analyse our records; identify new candidates or contractors; or prevent or detect fraud. We may also receive information about you from social media platforms including, but not limited to, when you interact with us on those platforms or access our social media content. Please note that the information we may receive is governed by the privacy settings, policies, and/or procedures of the applicable social media platform, and we encourage you to review them.

 

  1. How the Company uses this Personal Information

 

We will only use your personal information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:

 

  • To provide you with work-finding services.
  • To respond to your enquiries
  • To send you marketing communications and other information or material that may be of interest to you or which you have expressed an interest in receiving
  • To maintain our list of contacts
  • To maintain records relating to your employment status
  • As we believe reasonably necessary or appropriate to: comply with our legal obligations, respond to requests for information issued by government authorities or other third parties; or protect your, our, or others’ rights.

 

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so,

 

  1. Grounds for using your Personal Information

 

We rely on legal grounds to process your personal information, namely:

 

  • Candidates

 

  • Performance of a contract – We also use your personal information where it is necessary in accordance with the terms of our contract with you to assist in finding you employment opportunities.

 

  • Consent - We will use information we collect and as described in this policy subject to your consent. To withdraw your consent to such use, please email. We will rely on your consent for direct marketing and to collect information from your device or computer.

 

  • Contractors

 

  • Performance of a contract – We may need to collect and use your personal information to enter into a contract with you or to perform a contract that you have with us.

 

  • Legal obligation – we may need to collect and use your personal information to comply with legal obligations to which the Company is subject.

 

  • Legitimate interests – We may use your personal information for our legitimate interests to improve our services. Consistent with our legitimate interests and any choices that we offer or consents that may be required; we may use personal information for our marketing purposes.

 

  • Consent - We will use information we collect and as described in this policy subject to your consent. To withdraw your consent to such use, please email. We will rely on your consent for direct marketing and to collect information from your device or computer.

 

  • Contacts at employers

 

  • Legitimate interests – We may use your personal information for our legitimate interests in the course of performing our contract with the employer and to improve our services. Consistent with our legitimate interests and any choices that we offer or consents that may be required; we may use personal information for our marketing purposes.

 

  1. How we use Special Category Data

 

“Special Category Data” is particularly sensitive personal information which requires higher levels of protection.  Examples of “Special Category Data” are in section 1.  We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of data in the following circumstances:

 

  • With your explicit written consent. Usually this consent will be a one-off and will not permit us to continue to process your special category data indefinitely.
  • Where we need to carry out our legal obligations and in line with this policy
  • Where it is needed in the public interest, such as for equal opportunities monitoring and in line with this policy
  • Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

 

  1. Data Sharing

 

For Candidates and Contractors we will share your information with potential employers in the course of providing employment/recruitment services.  Before doing so we will always seek your consent and all potential employers we deal with are subject to obligations of confidentiality in respect of this information.

 

We do not sell, rent or otherwise share information that reasonably identifies you with unaffiliated entities for their independent use except as expressly described in this Privacy Policy or with your prior permission.

 

As part of the work-finding services, we may share Personal Information with potential employers within the European Economic Area (EEA) and the Crown Dependencies. There is an adequacy decision by the European Commission in respect of Guernsey, Jersey and the Isle of Man so these are considered to provide an adequate level of protection for your personal information.   

 

We may also disclose information we collect to third-party service providers that perform services on our behalf or alternatively to law enforcement or government authorities as may be required by us by law.  If we do share your Personal Information in this way you can expect a similar degree of protection.

 

If the Company’s business is sold or integrated with another business, your details may be disclosed to our advisers, and any prospective purchasers and their advisers, and will be passed on to the new owners of the business.

  1. Data Security Procedures

 

The Company takes every precaution to protect your Personal Information. Details of these measures are available upon request.

 

We have put in place appropriate security procedures to prevent your Personal Information from being accidentally lost, used or access in an unauthorised way, altered or disclose. In addition, we limit access to your Personal Information to those employees 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.

 

We have put in place procedures to deal with any suspected data security breach and will notify you and the regulators of a suspected breach where we are legally required to do so.

 

  1. Your rights

 

  • Updating Personal Information

It is important that Personal Information we hold about you is accurate and current. If your Personal Information changes (such as your address or surname) or is incorrect, please inform us and we will endeavour to update the Personal Information as quickly as possible.  

 

  • Data Subject Access Request

This enables you to receive a copy of the Personal Information we hold about you and check that we are lawfully processing it. If this request is made, then the data will be provided to you for free within four weeks of the request.

 

  • Request erasure of Personal Information

This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have exercised your right to object to processing (see below). In this circumstance the data will be erased within one month of the request.

 

  • Object to processing of your Personal Information where we are relying on a legitimate interest or for direct marketing

Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, you are entitled to do so. You also have the right to object where we are processing your personal information for direct marketing purposes.

 

 

  • Request the restriction of processing of your Personal Information

This enables you to ask us to suspend the processing of Personal Information. For example, if you want us to establish its accuracy or the reason for processing it.

 

  • Request the transfer of your Personal Information

This enables you to request that the Personal Information be transferred to another party.

 

  • Right to withdraw consent

Where you 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. 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.

 

If you wish to exercise any of the foregoing rights, please contact Jenny Mitchell or Melissa Campbell at team@situations.gg. No fee is required to access your Personal Information or exercise any of the other rights. We may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

 

We may request specific information from you to help us to confirm your identity and ensure your right to access the information or exercise any of your other rights.

 

  1. Data Retention

 

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for.  To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

In some circumstances, we may 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.

 

  1. Changes to the Privacy Policy

 

If we decide to change our Privacy Policy, we will post those changes on our website home page, so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it.  We will use information in accordance with the privacy policy under which the information was collected.

 

This policy was last updated on 22nd March 2018.

 

  1. Complaints or Queries

 

The Company tries to meet the highest standards when collecting and using personal information. We take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

If you wish to contact the Company in relation to this Privacy Policy or how we handle your personal information, please email: Jenny Mitchell or Melissa Campbell – team@situations.gg

Data Protection Authority

 

You have the right to make a complaint at any time to the supervisory authority for data protection issues:

Name               Guernsey Data Protection Commissioner

Telephone         01481 742074

Email                enquiries@dataci.org

Furthermore, you have the right to appeal to the Court against a determination by the Guernsey Data Protection Commissioner.

Website Policy

 

The Company collects information from our users at several different points on our website. The Company is the sole owner of the information collected on this site.  We will not sell, share or rent this information to third parties without your specific prior permission.

 

Cookies

 

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

The table below explains the cookies we use and why.

Cookie

Purpose

More information

Google Analytics

Site visitor analytics

Provides a way for us to track how many users use our site, and what devices / browsers they are using so that we can provide the best possible experience

Favourites

Store a list of the favourite jobs you have selected

Enables us to see which jobs you chose as favourites when you proceed to register with us

Facebook

Site visitor analytics

Provides a way for us to track how many users use our site, and what devices / browsers they are using so that we can provide the best possible experience

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.  Please note that in a few cases, some of our website features may not function if you remove cookies from your browser.

 

Log Files

 

We use IP addresses to analyse trends, administer the site, track users’ movements and to gather broad demographic information for aggregate use.  IP addresses are not linked to personally identifiable information.

 

Links

 

This website contains links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites.  We encourage you to be aware of this when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information.  This privacy statement applies solely to information collected by the Company’s website.

 

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