Privacy Notice for recruitment using Teamtailor
The service for handling recruitments and simplifying the hiring process (the "Service") is powered by Teamtailor on behalf of David Kennedy Recruitment ("Controller" "we" "us" etc.). It is important that the persons using the Service ("Users") feel safe with, and are informed about, how we handle User's Personal Data in the recruitment process. We strive to maintain the highest possible standard regarding the protection of Personal Data. We process, manage, use, and protect User's Personal Data in accordance with this Privacy Notice ("Privacy Notice").
1. General
We are the controller in accordance with applicable data protection laws. The Users' Personal Data is processed with the purpose of managing and facilitating recruitment of employees to our business.
2. Collection of Personal Data
We are responsible for the processing of the Personal Data that the Users contribute to the Service, or for the Personal Data that we in other ways collects with regards to the Service.
When and how we collect Personal Data
We collect Personal Data about Users from Users when Users;
- make an application through the Service or otherwise, adding Personal Data about themselves either personally or by using third-party source such as Facebook or LinkedIn; and
- use the Service to connect with our personnel, adding Personal Data about themselves either personally or by using a third-party source such as Facebook or LinkedIn.
- provides identifiable data in the chat (provided through the website that uses the Service) and such data is of relevance to the application procedure;
We collect data from third parties, such as Facebook, LinkedIn and through other public sources. This is referred to as "Sourcing" and can be manually performed by our personnel or automatically in the Service.
In some cases, our existing personnel can make recommendations about potential applicants. Such personnel will add Personal Data about such potential applicants. In the cases where this is made, the potential applicant is considered a User in the context of this Privacy Notice and will be informed about the processing.
The types of Personal Data collected and processed
The categories of Personal Data that can be collected through the Service are as follows: names, e-mails, pictures and videos, information from Facebook and LinkedIn-accounts, answers to questions asked through the recruitment process, titles, education work permits/visas, remuneration details and other information that the User or others have provided through the Service. Only data that is relevant for the recruitment process is collected and processed.
Purpose and lawfulness of processing
We collect and process your data for the following purposes:
- to provide recruitment services to you;
- to match your details against job vacancies which we consider are appropriate for you in order to assess your suitability for them;
- to allow you to submit your CV, apply for specific jobs or to subscribe to our job alerts so that we can notify you when relevant job vacancies arise;
- to apply for jobs on your behalf;
- to facilitate the recruitment process;
- to answer your questions;
- to conduct statistical analysis;
- to comply with our legal and regulatory obligations;
- conduct pre-employment screening;
- to provide you with further information which may be of interest to you regarding the employment market and opportunities;
3. Lawful basis for processing
If you are located in a region that requires a legal basis for processing of Personal Data (such as the EEA, or UK), we need a lawful basis pursuant to applicable data protection laws to collect, use and disclose your Personal Data where we are a controller. Our legal basis will depend on the information concerned and the context in which it is processed. We will typically collect and use your information as follows:
- Performance of a contract - where, in order to perform our obligations under a contract with you or to take steps at your request to enter into a contract with us, it is necessary for us to process your Personal Data.
- Compliance with a legal obligation - where we need to process your Personal Data to comply with legal or regulatory obligations.
- Our legitimate interests or those of a third party - including:
- Providing our services to you.
- Responding to your requests and enquiries (our the legitimate interest in this case is to maintain a constant and updated communication with clients and candidates, which is part of any commercial relationship).
- Optimising the performance of our website and user experience.
- Informing you about our services (job opportunities, industry reports and insights, events, promotions and competitions).
- Ensuring that our operations are conducted in an efficient manner.
- Providing satisfaction surveys of our services.
- Contacting prospective business clients in order to establish commercial relationships with business clients.
During the course of the services we provide, we may collect Personal Data that is considered sensitive or a special category data in certain countries. We will only collect sensitive Personal Data in accordance with the applicable data protection laws, in particular where it is necessary to comply with employment law for social protection purposes, for establishing, exercising, or defending legal claims or where we are required by law to collect such Personal Data.
4. Storage and transfers
The Personal Data collected through the Service is stored and processed inside the UK or EEA, such third country that is considered by the European Commission to have an adequate level of protection, or processed by such suppliers that have entered into such binding agreements that fully complies with the lawfulness of third country transfers (such as Standard Contractual Clauses) or to other suppliers where the adequate safeguards are in order to protect the rights of the data subjects whose data is transferred. To obtain further information regarding such safeguards, contact us using the contact details listed in paragraph 9.
5. Data Retention
Personal Data which we collect will be stored and processed by us as long as we deem it necessary with regards to the purposes stated above. We are conscious that a User may be interested in future recruitment opportunities and for this reason we may store Users' Personal Data until they are no longer of value as potential candidates. If you as a User wish not to have your Personal Data processed for this purpose (future recruitment) please contact us using the contact details in paragraph 9.
6. Users' rights
Under certain circumstances, by law Users have the right to:
- Request access to your personal information (commonly known as making a "data subject access request"). This enables Users to receive a copy of the personal information we hold about Users and to check that we are lawfully processing it. We will conduct a reasonable and proportionate search for your personal information.
- Request rectification of the personal information that we hold about you. This enables Users 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 Users 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 our data protection officer whose contact details are set out at paragraph 9 below.
The User has the right to lodge a complaint to the supervisory authority regarding the processing of Personal Data relating to him or her, if the User considers that the processing of Personal Data infringes applicable data protection laws.
7. Security
We prioritize the personal integrity and therefore works actively so that the Personal Data of the Users are processed with utmost care. We take the measures that can be reasonably expected to the make sure that the Personal Data of Users and others are processed safely and in accordance with this Privacy Notice and applicable data protection laws.
However, transfers of information over the internet and mobile networks can never occur without any risk, so all transfers are made on the own risk of the person transferring the data. It is important that Users also take responsibility to ensure that their data is protected. It is the responsibility of the User that their login information is kept secret.
8. Transfer of Personal Data to third parties
We will not sell Users' Personal Data to third parties.
We may transfer Users' Personal Data to;
- our contractors and sub-contractors, acting as our Processors and Sub-Processors in accordance with our instructions, for the provision of the Service;
- authorities or legal advisors in case criminal or improper behavior is suspected; and
- authorities, legal advisors or other actors, if required by us according to law or authority's injunction.
We will only transfer Users' Personal Data to third parties that we have confidence in. We carefully choose partners to ensure that the User's Personal Data is processed in accordance with applicable data protection laws. We cooperate with the following categories of processors of Personal Data; Teamtailor, who supplies the Service, server and hosting companies, e-mail reference companies, video processing companies, information-sourcing companies, analytical service companies and other companies with regards to suppling the Service.
9. Aggregated data (non-identifiable Personal Data)
Personal Data that is processed with the purpose of aggregated analysis or market research is always made unidentifiable. Such Personal Data cannot be used to identify a certain User. Thus, such data is not considered Personal Data.
We may share aggregated data with third parties. The aggregated data has in such instances been compiled from information that has been collected through the Service and can, for example, consist of statistics of internet traffic or the geological location for the use of the Service. The aggregated data does not contain any information that can be used to identify individual persons and is thus not Personal Data.
10. Cookies
When Users use the Service, information about the usage may be stored as cookies. Cookies are passive text files that are stored in the Internet browser on the User's device, such as computer, mobile phone or tablet, when using the Service. We use cookies to improve the User's usage of the Service and to gather information about, for example, statistics about the usage of the Service. This is done to secure, maintain and improve the Service. The information that is collected through the cookies can in some instances be Personal Data and is, in such instances, regulated by our Cookie Policy.
Users can at any time disable the use of cookies by changing the local settings in their devices. Disabling of cookies can affect the experience of the Service, for example disabling some functions in the Service.
11. Changes
We have the right to, at any time, make changes or additions to the Privacy Notice and the updated Privacy Notice will be published on the Service. The latest version of the Privacy Notice will always be available through the Service.
12. Contact
For questions, further information about our handling of Personal Data or for contact with us in other matters, please use the below stated contact details;
David Kennedy Recruitment david@davidkennedyrecruitment.com.
