C&M Recruitment Ltd (C&M) specialises in the recruitment of professionals at all levels, placing into permanent, contract and temporary vacancies within the travel industry. This means that C&M provides recruitment services to individuals, whether they are looking for a permanent job, or whether they are looking for their next assignment, with a view to helping these individuals fulfil their career aspirations with some of the best companies and most exciting roles and assignments in this sector.
In this policy, references to C&M, “we”, “us” or “our” means C&M Recruitment Ltd with company number 03526223. Our registered trading address is 7-10 Chandos Street, Cavendish Square, London, W1G 9DQ. Similarly, references to “you”, “yours” means you, the candidate.
WHAT IS THE PURPOSE OF THIS DOCUMENT?
C&M is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are a “data subject”, which means that you benefit from certain privacy rights as an individual.
This policy applies to you when we process your personal data with a view to asking us to help you with your job hunt, or when you are making an application for one of the vacancies or assignments that we have advertised or brought to your attention. These vacancies could be for a position as an employee or as a worker at one of our clients. `
This policy makes you aware of how and why your personal data will be used, namely for the purposes of providing you with high quality recruitment services, and also sets out how long we will usually keep your data. The policy provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
DATA PROTECTION PRINCIPLES
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
In connection with the provision of recruitment services that we conduct on your behalf, we will collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae and covering letter.
- The information you have provided via any online form, job board, application form or public social media platform including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications.
- Any information you provide to us during an interview, whether face to face, over email, by video conference or by telephone.
- From time to time, and if our clients require it, we may also ask you to take tests related to the job role, and in that case, any results of those tests.
We may also collect, store and use the following “special categories” of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about candidates from the following sources:
- You, the candidate.
- Social Media Platforms used for professional purposes and that are in the public domain (such as Linked In, Twitter and Facebook), and to the extent that you have opted to share your information with recruiters via the terms and conditions that you have accepted with those social media platforms. The data we collect from these platforms includes name, career history, job titles, contact information, address.
- Disclosure and Barring Service in respect of criminal convictions from time to time, and if so requested by our clients depending on the nature of the role they wish to fill.
- Your named referees, from whom we collect the following categories of data: career history, job titles
- Information that you have supplied to a job board via your agreement with that job board which we have access to following a paid-up subscription. A list of these job boards is available on request.
HOW WE WILL USE INFORMATION ABOUT YOU
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the role, and in accordance with our clients’ requirements.
- Carry out background and reference checks, where applicable, and if so requested by our clients pursuant to their instructions for staffing the role.
- Communicate with you about the recruitment process.
- Keep records related to our selection processes and successful recruitments or placements at our clients.
- Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to forward your profile to our clients, since it would be beneficial to our business to put someone forward who matches our clients’ requirements. We also have contractual obligations to provide suitable candidates to our clients.
Having received your personal data, such as your CV, work and employment history and qualifications, we will then process that information to decide whether you meet the basic requirements to be shortlisted for a role at one of our clients. If you do, we will decide whether your application is strong enough to invite you for an interview, after having considered our clients’ requirements. If we decide that your profile is a good match for any of our clients, then we will always contact you to talk to you about the role, provide you details about the client, and ask you for your consent for us to pass your personal data on to our client for consideration.
Please note that we will never pass your details on to our clients without first having obtained your express consent to do so.
If you provide us with your consent, then we will pass your details onto our client for consideration, and if our client agrees, we will call you to arrange an interview at our client. This may mean that we need to provide your contact details to our client directly so that they can contact you for logistical reasons and finalise the date, time and place of the interview. We will always ask you to confirm that you are happy for us to pass your details onto the client for this purpose.
On occasion, our client may request that we conduct interviews with you beforehand as part of the screening process that we have agreed with them. If that is the case, then we will inform you of this fact and use your personal data to arrange an interview with one of our recruitment consultants, provided that you agree.
If you have an interview at any of our clients, the client will then provide us with any information you provided to it at the interview in order for us to fulfil our contractual obligations to the client in assisting them with their recruitment needs and using our expertise to ensure that any appointment or engagement is a good fit.
Ultimately, it is always up to our client to decide whether to offer you the role or assignment. If our client does decide to offer you the role or assignment, then we or our client will then take up references and/or carry out a criminal record and/or carry out any other check that our client may so require before a formal offer of appointment is made.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your profile in accordance with individual client requirements (such as evidence of qualifications or work history), we might not be able to process any application or provide our recruitment services to you successfully. For example, if our client requires a credit check or references for a role and you fail to provide us with relevant details, we might not be able to take your application further, but we will always ensure that we put your best interests first, whilst acting on our client instructions.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
We will use your particularly sensitive personal information in the following ways:
- We may use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made by us or by our clients during a test or interview.
- We may use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting. Our Equal Opportunities Form is always provided anonymously and will never be communicated to the individuals making hiring decisions unless where required to do so by law.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We will only share your personal information with the following third parties for the purposes of processing your application: for example, with our clients. We will only ever share this information with your consent. Other third parties might involve IT service providers or CRM systems, data storage or hosting providers, CV parsers, data analysis services or accounts departments in the event of contract placements.
In this case, all our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. This also goes for our clients.
On occasion, some of those third-party recipients may be based outside the European Economic Area (EEA), for example, for storage on servers based outside of the EEA. Sometimes, countries outside of the EEA do not have the same data protection laws as the United Kingdom and the EEA.
Therefore, if we do transfer your personal information outside of the EEA, we will always ensure that appropriate or suitable relevant safeguards, such as the Standard Contractual Clauses, or as otherwise specified in the General Data Protection Regulation are applied, in order to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. If you would like further information, please contact us at email@example.com. We will not otherwise transfer your personal data outside of the EEA or to any international organization.
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.
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.
How long will you use my information for?
We will retain your personal information for a period of two years after our last meaningful communication with you. We consider that two years is reasonable, as this reflects the average lifecycle of an individual’s employment with any single employer, and so it is still in our interests and yours to keep your personal data for this period.
We also retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise for our clients in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.
If we wish to retain your personal information on file, for example, if we have not been able to immediately find you a suitable role or assignment, or if you had an unsuccessful application, on the basis that a further opportunity with other clients may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data 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.
- 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 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).
- Object to processing of your personal information 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 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 about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact firstname.lastname@example.org.
CONSENT OR LEGITIMATE INTERESTS
The basis on which we lawfully process your personal data depends on how we got in touch with you.
If you provided us with your personal data directly, for example, voluntarily by email, we consider that you provided consent to us processing your personal information for the purposes of providing recruitment services or for a specific job role.
If you submitted your personal data via a contact form on our website, and you positively ticked the relevant privacy and communications boxes before you clicked “send”, we also consider that you provided us with your consent to process the data you provided to us, again with a view to providing you with recruitment services or for a specific job role.
You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
JOB BOARDS OR SOCIAL MEDIA PLATFORMS
In the event that you posted your details on a job board or on social media with the “Visible to Recruiters” option ticked, we follow the guidance provided by Information Commissioner (the UK Data Protection Supervisor or ICO). We therefore consider that the lawful basis for processing personal data in this situation, on behalf of you, us as a recruitment agency and for our clients is in everyone’s legitimate interests.
In this instance, we consider that when you have made your details available in this way, this represents your express wish for future employers and recruiters being able to access this data. You might not have specifically had C&M in mind when you submitted your personal data to the relevant platform, but it is fair to consider that when doing so, you clearly expect that recruitment agencies, such as C&M, would access your data for the purpose of finding suitable profiles for our clients.
We consider that our legitimate interests as a recruitment agency and those of our clients to fill vacancies are not out of balance with your interests or rights as an individual when you have made your personal data available in this way. We consider that in this instance, our legitimate interests are likely to align with yours, as the aim for all of us is to find you a new job or assignment.
Any contact we make with you via job boards or social media is always carried out in compliance with the GDPR and other legal requirements (such as rules related to direct and electronic marketing (“PECR”) which govern how we can contact you by email and SMS.
However, if an individual has not selected the “Visible to Recruiters” option, then we will never assume that those individuals wish to be contacted for work.
In this case, in accordance with the ICO guidance, we consider that the individual privacy rights override our legitimate interests as a recruitment agency and we would always seek the individual’s consent before any information is taken from their profile.
When we obtain data from social media from third party providers (such as via plug-ins or apps), we will always ensure that these providers are contractually bound to adapt their technology so that details of individuals who do not have public profiles or who are not actively set as job-seekers are not sent to us.
Of course, if you have any queries relating about the information available on your social media profiles, then this is governed by your user agreement with each social media platform, and not with C&M. In this instance, we suggest that you check your privacy settings directly with the platform, and ensure that you raise any queries with them directly.
If you have any questions about this privacy notice or how we handle your personal information, please contact firstname.lastname@example.org. Whilst we always aim to resolve any complaints amicably, you also have the right to make a complaint at any time to the ICO.
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