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At MarketSmart Limited t/a RecruitEasy ("RecruitEasy") we are committed to both respecting and protecting your privacy. 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.
Your 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:
This Privacy Notice is provided in accordance with the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018, and, where applicable, the Privacy and Electronic Communications Regulations 2003 ("PECR").
For the purposes of data protection law, 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 Manny Hussain
Email: privacy@recruiteasy.co.uk
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:
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:
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.
When you visit our Website RecruitEasy will automatically collect the following information:
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.
We may record interactions with our services to improve the quality of our offerings, develop new features, and enhance user experiences. These recordings may include text, audio, video, or other data exchanged during your interaction. The data collected will be used strictly for the purposes of:
We take privacy and data security seriously. Any recordings used for training purposes will be anonymised and processed in accordance with our Data Protection policy. We will not associate the recordings with identifiable personal information unless explicitly required to fulfill a specific request or obligation, in which case we will seek your consent beforehand.
If you prefer not to have your interactions recorded for training purposes, you may opt out by contacting us at privacy@recruiteasy.co.uk. Please note that opting out may limit our ability to improve certain features of the service.
RecruitEasy use information held about you in the following ways:
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).
RecruitEasy uses artificial intelligence ("AI") tools to assist our consultants with recruitment, compliance, document handling, search, matching and workflow efficiency. These tools are assistive only. They do not make final decisions about candidates, clients, placements, progression, rejection, or any other outcome that may have legal or similarly significant effects on an individual.
Where we use external AI providers, this currently includes OpenAI and Google Gemini. Google Gemini services are used through paid business services and/or Google Cloud Vertex AI under contractual and technical controls. We do not use consumer AI services for candidate decision-making workflows.
All AI outputs are reviewed by an authorised RecruitEasy staff member before they are relied on in a recruitment, compliance, or operational context. Meaningful human review is always applied. Individuals may ask for human review of any materially AI-influenced outcome and may contest a decision in accordance with the rights set out in this notice.
RecruitEasy uses AI tools, including Google Gemini, to process CVs and related candidate documents. This may include text understanding, document parsing, image understanding, PDF analysis, structured extraction, summarisation, classification, reformatting, skill identification, chronology extraction, and document comparison.
This means that where a CV or supporting document is uploaded in PDF, scanned, image, or similar format, the AI system may analyse both the visible content and the text content of that document in order to identify and extract relevant information. This is a form of automated processing of personal data.
The categories of information extracted may include, for example: name, contact details, work history, education, qualifications, professional memberships, right-to-work information, availability, salary information, skills, certifications, location, languages, and other information contained in the CV or supporting documents.
In some cases, the AI system converts CV content into structured fields or structured JSON outputs so that information can be searched, filtered, quality checked, and displayed consistently inside our systems. This structured extraction is used to support consultant review and internal workflow only.
CVs and recruitment records may contain special category data or other sensitive information, including information relating to health, disability, racial or ethnic origin, religion, trade union membership, sexual orientation, criminal records, or other protected characteristics. Where such information is present, we process it only where a lawful basis and, where required, an Article 9 condition applies.
RecruitEasy does not use Google Gemini or any other AI tool to make solely automated decisions about individuals. We do not use special category data to allow an AI model to autonomously determine whether an individual should or should not be hired, shortlisted, rejected, or progressed. Where sensitive data appears in a CV or supporting document, it is handled under access controls, restricted workflows, and human oversight.
We instruct our AI providers not to use our customer data to train general models unless we expressly agree otherwise. For Google Gemini paid services and Vertex AI, Google states that customer data is not used to improve its products in paid Gemini API use, and that Google will not use customer data to train or fine-tune AI/ML models without prior permission or instruction.
Where RecruitEasy uses Google Gemini, processing is restricted to paid business services and configured regional endpoints intended to keep AI processing within the United Kingdom and/or European Economic Area, in line with our internal data protection impact assessment and regional deployment controls.
Where Google Gemini is accessed through Vertex AI regional services, machine learning processing occurs within the specific region or multi-region where the request is made. RecruitEasy configures those services to use UK and/or EEA locations only for the relevant workflow.
RecruitEasy also applies a zero data retention configuration for Vertex AI services where available and appropriate to the workflow. This means we configure the service so that prompts, files, outputs and derived data are not retained longer than necessary for the requested operation, except where temporary technical processing, in-memory caching, security controls, logging, or an enabled feature requires limited short-term handling.
Where the Google Gemini Files API is used to upload documents for processing, uploaded files may be temporarily stored by Google for up to 48 hours before deletion. This temporary storage is used to support the requested file-processing operation. We do not use that temporary file storage as a long-term document repository.
We do not permit Google Gemini paid services to use candidate CVs, prompts, outputs, or related personal data to train Google’s general models for RecruitEasy workflows.
AI may help us:
AI does not:
Some AI features used by RecruitEasy may amount to automated processing or profiling under data protection law because they analyse personal data and generate scores, flags, classifications, recommendations, rankings, summaries, or structured outputs. These outputs are used as decision-support tools only.
RecruitEasy does not carry out solely automated decision-making that produces legal effects or similarly significant effects on candidates or other individuals. Any recruitment, suitability, compliance, or progression decision is reviewed by a human decision-maker with authority to accept, reject, override, or disregard the AI output.
Our safeguards include:
RecruitEasy retains AI-related records only for as long as necessary for recruitment, compliance, legal, operational, and audit purposes. Unless a shorter retention period applies by law or policy:
Our lawful basis for AI-assisted processing will depend on the context. In most cases this will be our legitimate interests in operating an efficient, consistent and secure recruitment service, performance of a contract, compliance with legal obligations, or, where required, explicit consent or another valid condition for special category data.
You have the right, subject to applicable law, to:
To exercise these rights, please contact us using the details set out in this notice.
RecruitEasy aims to use AI systems responsibly, proportionately, and with appropriate human oversight. We recognise that AI systems can produce errors, incomplete outputs, or outputs that may reflect bias present in training data, source documents, or system design.
To reduce these risks, we apply governance and control measures which may include:
We also seek to ensure that AI-assisted processing is fair and does not replace human judgment in recruitment, compliance, or progression decisions.
While we aim to provide meaningful information about our use of AI, there may be practical and legal limits to the level of technical detail we can provide in every case, including where this would affect the rights of others, confidential information, security, or proprietary systems. Even so, we will seek to provide a clear explanation of the role AI played in the processing of your personal data where required by law and reasonably possible.
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.
Where personal data is transferred outside the United Kingdom or, where applicable, the European Economic Area ("EEA"), we will ensure that appropriate safeguards are in place as required by applicable data protection law.
These safeguards may include one or more of the following:
Where required, we also carry out and document transfer risk assessments and apply supplementary contractual, organisational, and technical measures designed to protect personal data transferred internationally.
You may contact us using the details in this notice if you would like more information about the safeguards used for a specific transfer of your personal data.
We process personal data only where we have a lawful basis to do so. The lawful basis depends on the purpose of the processing. The table below summarises the main lawful bases we rely on.
| Purpose of Processing | Typical Categories of Data | Lawful Basis |
|---|---|---|
| Registering candidates, assessing suitability, arranging interviews and placements | Identity, contact details, CV data, work history, qualifications, right-to-work and related recruitment data | Legitimate interests; performance of a contract; steps prior to entering into a contract |
| Managing client relationships and providing recruitment services to clients | Business contact details, role requirements, communications, placement information | Legitimate interests; performance of a contract |
| Compliance checks, legal and regulatory obligations | Identity data, right-to-work information, financial and compliance documentation | Legal obligation; substantial public interest where applicable |
| Sending marketing communications about services, vacancies, events or updates | Name, email address, phone number, marketing preferences | Consent where required by law; otherwise legitimate interests |
| Website administration, security, fraud prevention, troubleshooting and analytics | IP address, browser data, technical logs, usage data | Legitimate interests; legal obligation where applicable |
| AI-assisted CV parsing, document analysis, matching, summarisation and workflow support | CVs, candidate documents, application materials, extracted structured data, audit logs | Legitimate interests; performance of a contract; legal obligation; and where required, explicit consent or another valid condition for special category data |
Where we process special category data, criminal offence data, or other sensitive information, we do so only where a valid lawful basis and any additional condition required by law applies.
Our Website and recruitment services are intended for adults and business users. They are not directed at children, and we do not knowingly collect personal data from anyone under the age of 16 through the Website as part of our standard services.
If we become aware that we have collected personal data from a child without a valid lawful basis or, where required, appropriate consent, we will take reasonable steps to delete or restrict that data as soon as practicable.
If you believe that a child may have provided us with personal data, please contact us at privacy@recruiteasy.co.uk.
We aim to collect and process only the personal data that is relevant and reasonably necessary for the purposes described in this notice. We do not intentionally collect excessive personal data and take steps to limit the use of personal data to what is needed for recruitment, compliance, operational, legal, security, and related business purposes.
We also take reasonable steps to keep personal data accurate and up to date. This may include checking information with you, updating records during our interactions with you, and verifying information from lawful external sources where appropriate.
We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access.
Depending on the nature of the data and processing, these measures may include:
While we take appropriate steps to protect personal data, no system or transmission method over the internet can be guaranteed to be completely secure.
We maintain procedures for identifying, investigating, recording, and responding to personal data breaches.
Where we are legally required to do so, we will notify the Information Commissioner’s Office ("ICO") and, where relevant, affected individuals, without undue delay. This includes cases where a personal data breach is likely to result in a risk, or a high risk, to the rights and freedoms of individuals.
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.
RecruitEasy will use this information:
Automated Decision-Making: RecruitEasy do not carry out solely automated decision-making. AI tools may be used to assist in the processing and organisation of candidate data, but a RecruitEasy consultant will always be responsible for and involved in any decision made about a candidate.
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:
RecruitEasy will disclose your personal information to third parties:
The lawful basis for the third-party processing will include:
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.
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:
The criteria RecruitEasy use to determine whether we should retain your personal data includes:
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.
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:
The Data Protection Act 2018 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 privacy@recruiteasy.co.uk
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.
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 privacy@recruiteasy.co.uk
If you have concerns about how we collect, use, or protect your personal data, please contact us first so that we can try to resolve the issue.
You also have the right to lodge a complaint with the Information Commissioner’s Office ("ICO"), the UK supervisory authority for data protection matters.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
United Kingdom
Website: https://ico.org.uk/