Privacy Notice – Pembury Partners Recruitment Limited

Introduction

Welcome to our privacy notice.

Pembury Partners Recruitment Limited (“Pembury Partners”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), make contact with us or where we provide our recruitment services to you either as a client or a candidate. In this privacy notice, we tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how Pembury Partners collects and processes your personal data when providing our recruitment services (as a candidate or client) or through your use of this website. This includes any data that you may provide to us through this website, when you contact us online, by email, by phone or in person or when you sign up to receive emails from us.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

Controller

Pembury Partners Recruitment Ltd is the controller and responsible for your personal data (collectively referred to as “Pembury Partners”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy notice or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Pembury Partners Recruitment Ltd

Name or title of data privacy manager: Elvie Dakin

Email address: info@pemburypartners.co.uk

Postal address: Pembury Partners Recruitment Ltd, Suite 5, 3 Universal Square, Devonshire Street North, Manchester M12 6JH United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review. This version was last updated in November 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender.
  • Contact Data includes residential or professional address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of recruitment services we have provided to you.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes previous opportunities you have advertised or applied for, your CV or equivalent and personal data contained within it (including your employment history or background, salary, references and referees (and their personal data), professional qualifications, education details and academic qualifications and other similar information), other employment or work information (such as benefits package, professional development and training, professional membership, business plans and disciplinary record), your interests, preferences and any feedback and survey responses.
  • Usage Data includes information about how you use our website and recruitment services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Category Data and Data Relating to Criminal Convictions and Offences

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). However, where applicable as part of our recruitment services we may collect information about criminal convictions and offences.

We request that you do not provide us with any Special Categories of Personal Data.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our recruitment services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, Financial and Profile Data by filling in forms or contacting us via the website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • wish to use our recruitment services (whether as a client or a candidate) including when you respond to one of our current opportunities or upload or share your CV with us;
    • (where applicable) subscribe to our publications;
    • request marketing or information on our recruitment services or available opportunities to be sent to you (including alerts on latest job opportunities);
    • where you sign up for an event that we are organising; and
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU;
    • search information providers such as Google based outside the EU.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Paypal based outside the EU.
    • Identity, Contact and Profile Data from your referees (including former employers).
    • Identity, Contact and Profile Data from publically available sources such as Companies House, the Electoral Register, public social media accounts (including LinkedIn) and job boards.
  • Referees: where you have agreed to be a referee, we will be provided with your Identity and Contact Data for the purposes of obtaining a reference on a candidate.

4. HOW WE USE YOUR PERSONAL DATA

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

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where you have provided us with consent to do so (see below).
  • Where it is necessary for our legitimate interests (or those of a third party), including providing our recruitment services, and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

We only rely on consent as a legal basis for processing your personal data in limited circumstances which includes to put you forward for an available opportunity (we will also rely on legitimate interests as a legal basis for this processing) or before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to us processing your personal data for these purposes any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you for our recruitment services as a client or potential candidate

 

 (a) Identity

(b) Contact

(c) Profile

 (a) Performance of a contract with you

(b) Necessary for our legitimate interest
To carry out and provide our recruitment services including to:

(a) fill available opportunities;

(b) carry out required employment and background checks and to obtain references;

(c) manage payments, fees and charges; and

(d) collect and recover money owed to us

 

 (a) Identity

(b) Contact

(c) Financial

(d) Profile

(e) Transaction

(f) Marketing and Communications

 (a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

(c) Consent (to put you forward for an available opportunity)
To sign you up for an event that we are organising or for job alerts

 

 (a) Identity

(b) Contact

 (a) Necessary for our legitimate interests (to enable our business to grow)
To manage our relationship with you which will include:

(a) notifying you about changes to our terms or privacy notice

(b) asking you to leave a review or take a survey

 (a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 (a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

 
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

 
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

 Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences (a) Technical

(b) Usage

 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 
To make suggestions and recommendations to you about services or available opportunities that may be of interest to you (including to contact you via third party platforms such as LinkedIn) (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

 

 Necessary for our legitimate interests (to develop our products/services and grow our business)

Criminal Convictions or Offences

Where we collect and process data on criminal convictions or offences, we do so only in order to provide the recruitment services that you have requested we provide to you and so that we can perform any contract with you. We will obtain your explicit consent to collect and process this data and to share it with any selected third parties in order to provide and perform our recruitment services.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promoting our services

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you (including available opportunities that may be suitable or of interest to you). This is how we decide which services may be relevant for you (we call this marketing).

You will receive marketing communications from us (including notifications of available opportunities that may be of interest to you)  if you have registered your details with us, requested such communications from us or we have provided our recruitment services and you have not opted out of receiving such marketing communications.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, registering with us as a client or candidate for our recruitment services or for service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

  • External Third Parties as set out in the Glossary.
  • Where you are a potential candidate for an available opportunity, our clients for the purpose of carrying out our recruitment services.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

As part of our recruitment services we may transfer your personal data outside of the UK and the European Economic Area (EEA) within our internal business structure or to provide our recruitment services to you. We will take steps to ensure the protection of your personal data where we transfer it outside of the UK and the EEA for these purposes.

Some of our external third parties may be based outside of the UK and/or the EEA so their processing of your personal data may involve a transfer of data outside of the EEA.

Whenever we transfer your personal data outside of the UK and/or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

In addition to the above, we and/or or our external third parties may transfer personal data outside of the UK and/or the EEA to group companies under a set of rules that will protect the transfer of your personal data between a group of companies. These rules are called “binding corporate rules”. For further details, see European Commission: Binding corporate rules.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

8. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

  • Service providers acting as processors or controllers based in the United Kingdom who provide IT, website, telephone, payment, accounting, marketing, advertising, event, and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.