GDPR Data Protection & Privacy Policy

What is this Policy for?

At Marketsmart Limited t/a Recruiteasy (”Recruiteasy”) we are committed to both respecting and protecting your privacy. Your privacy is safe with us as a business registered with the Government under the Data Protection Act 1998 and Registration Number ZA167505.

“We”, “Us” or “Our” means Marketsmart Limited or one of its trading names or trading styles including for the purpose of this website the trading names of “Recruiteasy” or “recruiteasy.co.uk”.

“You” means the person, firm, company or organisation browsing and/or using this website and “your” shall be construed accordingly.

This notice together with our Website Terms & Conditions of Use and any other agreed documents sets out the basis on which any personal or business or commercial data we either collect from you, or that you or a legitimate source provide to us, will be processed.

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) (“GDPR”) replaces the Data Protection Regulation (Directive 95/46/EC). It aims to harmonise data protection legislation in the UK and across the EU member states enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

our rights under GDPR apply from 25 May 2018 and are set out in this notice.

For the purposes of data protection legislation in force from time to time the Data Controller is:

Marketsmart Limited t/a Recruiteasy, 1 Templer House, Scott Close, Newton Abbot, Devon, TQ12 1GJ

Our nominated Data Protection Officer is:

Mr Paul Donnelly

Who are Recruiteasy?

Recruiteasy are a legal recruitment agency and employment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We collect the personal data of the following types of people to allow us to undertake our core business and ancillary activities:

• Prospective or placed “Candidates” for permanent or temporary roles to include (but not limited to) our employees, temporary workers, consultants, contractors or sub-contractors
• Prospective and live clients or customers
• Supplier contacts or any other person or entity that we rely on to support the provision of our services

Information we collect about you or your give to us

This is information about you that you give us by visiting our website www.recruiteasy.co.uk (“Website”) or by corresponding with us by phone, e-mail, SMS or otherwise. It includes information you provide when you:

• Register as a candidate to enter our database or apply for jobs or information
• Register or enquire about a vacancy
• Subscribe to receive any information about the company, industry, jobs or vacancies
• Request a job to be emailed to you
• Download any information
• Refer colleagues or friends as part of our referral program or otherwise
• Enter a competition or take part in a survey or respond to an enquiry
• Register to attend an event that we organise
• Participate via social media or other functions on our Website
• Report a problem with our Website or Social Media platforms.

The information you give us or Recruiteasy collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae (or career profile) and photograph and data that may be held on your professional profile available in the public domain e.g. via social media sites or business media sites or job board sites.

Recruiteasy may need to collect and process sensitive personal data about you. The GDPR defines sensitive personal data as data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Information Recruiteasy collect about you when you visit our Website

When you visit our Website Recruiteasy will automatically collect the following information:

Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, operating system and platform.

Information about your visit, including the full Uniform Resource Locators (URL) of each page visited, clickstream to and through our Website including date and time, jobs visited and searched for, download errors, length of visits to pages, and any information submitted through forms.

Information Recruiteasy obtain from other sources

This is information Recruiteasy obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card and personal recommendations. You will have normally supplied this information to such third parties and given your permission for its distribution to businesses such as Recruiteasy.

Purposes of the processing and the legal basis for the processing

Recruiteasy use information held about you in the following ways:

To carry out our obligations arising from any contracts Recruiteasy intend to enter into or have entered into between you and Recruiteasy to provide you with the information and services that you request from us or that we think will be of interest to you because it is relevant to your career or to your organisation.

To provide you with information about other services or jobs that Recruiteasy offer that are similar to those that you have already been provided with or enquired about.

The core service Recruiteasy offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent recruitment. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.

Our legal basis for the processing of personal data is our legitimate interests, described in more detail below, although Recruiteasy will also rely on contract, legal obligation and consent for specific uses of data.

Recruiteasy will rely on any existing contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.

Recruiteasy will rely on legal obligations if we are legally required to hold information on you to fulfil our legal obligations.

Recruiteasy will rely on your consent for particular uses of your data and you will be asked for your express consent, if legally required e.g. when we are processing sensitive personal data or when gaining your permission to introduce you to a client (if you are a candidate).

Our Legitimate Interest

Our legitimate interest in collecting and retaining your personal data is described below:

As a recruitment agency and an employment business, Recruiteasy introduce candidates and agency workers to clients for placement as temporary workers, contractors, sub-contractors, independent professional contractors or permanent employment. The exchange of personal data of our candidates and our client contacts is a fundamental and essential part of this process.

In order to support our candidates’ career aspirations and our clients’ resourcing needs Recruiteasy require a database of candidate and client personal data containing historical information as well as current resourcing requirements.

To maintain, expand and develop our business Recruiteasy need to record the personal data of prospective candidates and client contacts.

Consent

Should Recruiteasy want or need to rely on consent to lawfully process your data Recruiteasy will request your consent either orally or written or by email or by SMS or by completing an online process for the specific activity (e.g. when registering a vacancy or as a candidate or when you apply for a job) when Recruiteasy will require your consent for and to record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

Other Uses Recruiteasy will make of your data:

• Use of our Website
• to notify you about changes to our service
• to ensure that content from our Website is presented in the most effective manner for you and for your computer or access device.

Recruiteasy will use this information:

• to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
• to improve our Website to ensure that content is presented in the most effective manner for you and for your access device or computer
• to allow you to participate in any interactive features of our service, when you choose to do so;
• as part of our efforts to keep our Website safe and secure
• to measure or understand the effectiveness of the information, news and job advertising Recruiteasy serve to you and others, and to deliver relevant information, news and job advertising to you
• to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.

Recruiteasy do not currently undertake automated decision making or profiling but may do so in the future. Recruiteasy use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always ultimately be involved in the decision-making process.

Disclosure of your information inside and outside of the European Economic Area (”EEA”)

Recruiteasy will share your personal information with:

Any member of our group both in the EEA and outside of the EEA.

Selected third parties including:

• clients (or a nominated party acting on behalf of our clients) for the purpose of introducing candidates to them
• candidates for the purpose of discussing job opportunities to them, the arranging of interviews and engagements
• clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract Recruiteasy enter into with them or you
• subcontractors including email marketing specialists, event organisers, payment and other financial service providers
• Recruiteasy may make use of the personal data we have collected from you to enable us to display our adverts to the correct targeted audience
• analytics and search engine providers that assist us in the improvement and optimisation of our Website
• credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.

Recruiteasy will disclose your personal information to third parties:

• In the event that Recruiteasy sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets
• If Recruiteasy or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets
• If Recruiteasy are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms of Use and other agreements; or to protect the rights, property, or safety of Recruiteasy, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The lawful basis for the third-party processing will include:

• Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs
• satisfaction of their contractual obligations to us as our data processor
• for the purpose of a contract in place or in contemplation
• to fulfil their legal obligations.

Where Recruiteasy store and process your personal data

The data that Recruiteasy collect from you may be transferred to, and stored at, a destination outside the EEA. It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Recruiteasy will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

All information you provide to us is stored on our secure servers. Where Recruiteasy have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. Recruiteasy ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although Recruiteasy will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to or via our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Retention of your data

Recruiteasy will retain your personal data for as long as necessary in order to provide the recruitment service to you and for the purposes of satisfying any legal, accounting, regulatory or reporting requirements.

Recruiteasy do the following to try to ensure our data is accurate:

• prior to making an introduction we will check that we have accurate information about you
• We keep in touch with you so you can let us know of changes to your personal data
• We make use of external websites (e.g. LinkedIn, facebook, Law Society) to verify the information about you.

The criteria Recruiteasy use to determine whether we should retain your personal data includes:

• the nature of the personal data and the nature of your consent
• the perceived accuracy of the data
• our legal obligations
• whether we have been active with you as part of our general recruitment service (e.g. discussing roles or vacancies with you, arranging interviews or placing you in a new role)
• our recruitment expertise and knowledge of the industry by country, sector and job role

Recruiteasy may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our systems. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data onto our database, unless requested to do so.

For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. Recruiteasy will usually inform you (before or during the process of collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.

Our Website may, from time to time, contain links to and from the websites of our partner networks, regulatory bodies, industry bodies and affiliates, advertisers and other affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms and that Recruiteasy do not accept any responsibility or liability for these websites and how they operate. Please check their policies and terms before you submit any personal data to these websites.

The GDPR provides you with the right to:

• Request correction of the personal information that Recruiteasy hold about you. This enables you to have any incomplete or inaccurate information 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 Recruiteasy 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 Recruiteasy 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 in certain formats, if practicable
• Withdraw your consent to the collection, processing and transfer of your personal data (“Opt-out”). You have the right to Opt-out at any time. Once we have received notification that you have Opted-out we will no longer process your personal data for the purpose of providing you with the Recruitment Service, unless we have another legitimate basis for doing so in law
• To Opt-out or withdraw your consent or to make any other changes to how we process your personal data please contact us by email to admin@recruiteasy.co.uk or through our website at www.recruiteasy.co.uk/contact supplying your name and contact details
• Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this web site: https://ico.org.uk

Access to information

The Data Protection Act 1998 and the GDPR give you the right to access information held about you. Recruiteasy also encourage you to contact us to ensure your data is accurate and complete. Please note that you will not usually need to pay a fee to access your personal data or to exercise any other rights. However, Recruiteasy may charge a reasonable fee if your access request for access is excessive. In such circumstances, we reserve the right to refuse to comply with the request.

A subject access request should be submitted by email to admin@recruiteasy.co.uk

Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website.

By using our Website you are agreeing to the use of cookies as described.

Changes to our Data Protection and Privacy Notice

Any significant changes Recruiteasy make to our Data Protection and Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back regularly to see any updates or changes.

Contacting Us

Questions, comments and requests regarding this Notice are welcomed and should be addressed to:

The Data Protection Officer

Marketsmart Limited t/a Recruiteasy, Unit 1, Scott Close, Newton Abbot, Devon, TQ12 1GJ

or via email to admin@recruiteasy.co.uk