Who we are and what we do
Grafham Walbancke Ltd, Tayfield House, Bournemouth, Dorset BH4
email@example.com 020 3800 0041
We are a recruitment agency and a recruitment business, as defined in the Employment Agencies and Employment Business Regulations 2003, and provide permanent and temporary recruitment services to clients looking to source IT / Sales / PreSales / Post Sales personnel for their businesses.
We collect the personal data of the following types of people to allow us to undertake our business activity:
• Prospective and placed candidates for permanent and/or temporary roles;
• Prospective and live client contacts;
• Supplier contacts to support our services;
• Current and former employees, contractors and temporary workers.
What does this Policy cover?
We at Grafham Walbancke Ltd are committed to protecting and respecting your privacy. This policy:
1. sets out the types of personal data that we collect about you;
2. explains how and why we collect and use your personal data;
3. explains how long we keep your personal data for;
4. explains when, why and with who we will share your personal data;
5. sets out the legal basis we have for using your personal data;
6. explains the effect of refusing to provide the personal data requested;
7. explains our stance on automated decision making;
9. explains our stance on transferring data outside the EEA;
10. explains the different rights and choices you have when it comes to your personal data; and
11. explains how we may contact you and how you can contact us.
What personal data do we collect about you?
Personal data 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 collect the information necessary to be able to find available opportunities and further information needed to assess your eligibility through the different stages of recruitment. This information includes, but is not limited to, CV’s, identification documents, educational records, work history, employment (possibly including salary and benefit details), references and links to your professional profiles available in the public domain, for example, LinkedIn.
Employees, Workers and Contractors
We may collect, store, and use the following categories of personal information about you:
• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
• Date of birth
• Marital status and dependants
• Next of kin and emergency contact information
• National Insurance number
• Bank account details, payroll records and tax status information
• Salary, annual leave, pension and benefits information
• Start date
• Location of employment or workplace
• Copy of driving licence and passport
• Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
• Employment records (including job titles, work history, working hours, training records and professional memberships)
• Compensation history
• Performance information
• Disciplinary and grievance information
• Information about your use of our information and communications systems
We may also collect sensitive personal data about candidates, employees, workers and contractors in the form of racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership or genetic or biometric data of information concerning an individual’s health, sex life, sexual orientation and criminal convictions information. We only collect sensitive personal data from you and further process this data, where you have given your explicit consent.
Where do we collect personal data about you from?
Candidates: The following are the different sources we may collect personal data about you from:
• Directly from you: This is information you provide while searching for a new opportunity and/or during the different recruitment stages. It may include information that you provide via emails, phone conversations, face to face meetings and website submissions.
• From an agent/third party acting on your behalf: For example, a Contractor’s Personal Service Company / Job boards where you uploaded your CV and personal information.
• Through publicly available sources: We use the following public sources:
o Corporate websites
o Job Board websites
o Online CV libraries
o Social media platforms
o Online portfolios/ blogs
o Technical IT User Groups
• By Reference or word of mouth: For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer.
Where we collect your information through publicly available sources as set out above, we may do this with the aid of software programs. These programs are given parameters on the requirements of a role and search through publicly available sources to find such candidates. These programs are designed to only output information on candidates that meet the search criteria. The parameters of these programs are restricted to only searching for candidate information such as name, job role, key skills and current/previous employers from public sites where there is a reasonable expectation that such information may be collected and further processed by job recruiters for the purpose of sourcing candidates for different job roles.
Employees, Workers and Contractors: We collect personal information through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.
How and why we use your personal data?
We use information held about you in the following ways:
• To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
• The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
• For candidates, we use your personal data to match your skills, experience and education with a potential employer. We will initially collect basic information on you such as contact details, job role and experience and then pass this on to the client in search of personnel. If you are chosen by the client and go through to the next stage we will then be collecting more information from you at the interview (or equivalent) stage and onwards in that manner.
How long do we keep your personal data for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
If you request that your details are completely removed from our database, then there is a chance that we may contact you again if your details are found through publicly available sources. We suggest that you allow us to minimise your data, so that we know not to approach you. Minimising data is when we retain basic identifying information (name, company name, email address and publicly available details, for example, a LinkedIn hyperlink).
Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Who do we share your personal data with?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. We will also share your personal information with third parties with whom you are seeking employment or engagement by engaging our services as recruitment consultants. We may also share your personal information with third parties to whom you are assigned to work while employed by us. This may include providing your prospective employer or the company to which you are assigned with sensitive personal data such as copies of your passport or other identity documents.
What legal basis do we have for using your information?
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on 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.
We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our database. Where consent is the lawful basis for our processing, you have the right to withdraw your consent to this particular processing at any time.
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment or temporary worker placements. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
For prospective candidates, contractors, referees and clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees.
If you are submitted as a candidate and interviewed, then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case we always ask for your consent before undertaking such processing.
For clients, we may also rely on our processing being necessary to perform a contract for you, for example in contacting you.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide certain information when requested, we may not be able to perform a contract that we have entered into, or we may be prevented from complying with our legal obligations. It is unlikely that we shall be able to proactively support candidates throughout their careers or support businesses with their resourcing needs & strategies.
Do we make automated decisions concerning you?
No, we do not carry out automated decision-making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
Do we transfer your data outside the EEA?
No, we do not transfer personal data out of the EEA.
What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
Rights What does this mean?
1 The right to be informed You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
3 The right to rectification You are entitled to have your information corrected if it’s inaccurate or incomplete.
4 The right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5 The right to restrict processing You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6 The right to data portability You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
7 The right to object to processing You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
8 The right to lodge a complaint You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
9 The right to withdraw consent If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
• baseless or excessive/repeated requests or;
• further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We shall respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we shall advise you accordingly.
How do I remove my details from your database?
We suggest that you allow us to minimise your data so that we know not to approach you. Minimising data is when we retain basic identifying information (name, company name, email address and publicly available details, for example, a LinkedIn hyperlink).
If you request that your details are completely removed from our database, then there is a chance that we may contact you again if your details are found through publicly available sources.
Please email: firstname.lastname@example.org post: Grafham Walbancke Ltd, Tayfield House, Bournemouth, Dorset BH4 with your request.
How will we contact you?
We may contact you by phone, text message, email, post or social media. If you prefer a particular contact means over another please just let us know.
How can you contact us?
If you are unhappy with how we’ve handled your information or have further questions on the processing of your personal data,
Please email: email@example.com post: Grafham Walbancke Ltd, Tayfield House, Bournemouth, Dorset BH4 with your request.
Please also refer to this information
View terms & conditions here.