ORANGE APPOINTMENTS LTD PRIVACY NOTICE
Orange Appointments Ltd (”We”)(“The Company”) are committed to protecting and respecting your privacy.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection legislation in force from time to time the data controller is Orange Appointments Ltd of Suite 308, Eagle Tower, Cheltenham, Gloucestershire, GL50 1TA.
Our Data Protection Officer is William Pearce (Director).
Who we are and what we do
We are a recruitment agency which provides work-finding services to its clients and candidates. We must process personal data so that we can provide these services – in doing so, the Company acts as a data controller.
Information you give to us or we collect about you
The information we collect about you will be provided by you, either by filling out a form on our website [www.orangeappointments.com] or by corresponding with us by phone, e-mail or otherwise. It will also include information you provide when you register to use our website, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our website, enter a competition, promotion or survey, and when you report a problem with our site.
The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with the terms of the following statement.
The information you give us or we 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 & experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, Facebook or corporate websites.
Information we obtain from other sources
We may also obtain information about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, and any relevant social media sites. In this case – and within 30 days of collecting – we will inform you that we hold this personal data, the source the data originated from, whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
Purposes of the processing and the legal basis for the processing
We may use your personal data to:
· Assess and verify your potential suitability for employment with a Client;
· Contact you in relation to any potential employment opportunities with a Client;
· Introduce you to our Clients and potentially arrange for you to fill a Client vacancy;
· Stay in regular contact with you to understand your current position, career aspirations and motivation for finding new employment;
· Where applicable, make payments to you or arrange for any third-party company through which you may contract to make payments to you;
· Contact you to ask for a referral;
· Produce anonymised statistical data;
· Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime; and
· Conduct equal opportunities monitoring.
If you are a Client Contact, we may use your personal data to:
· Contact you to obtain information about our Client’s requirements;
· Liaise with you so that we may effectively perform the services to our Client;
· Obtain a reference for a Candidate;
· Contact you for invoicing and credit control purposes;
· Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment agency we introduce candidates to clients for permanent employment, temporary placements or independent professional contracts. 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 store of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.
Consent
With consent, we will share your personal information with clients for the purpose of introducing candidates to them and candidates for the purpose of arranging interviews and appointments. Should we want or need to rely on consent to lawfully process your data we will request your consent orally or by email for the specific activity we require consent for. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Disclosure of your information inside and outside of the EEA
Your CV and related information will be sent to prospective employers but only where you give your consent. Such employers may be located both inside and outside the European Economic Area (EEA).
We may also release information relating to you to regulatory or law enforcement authorities, if required to do so.
We will disclose your personal information to third parties if Orange Appointments Ltd 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.
Where we store and process your personal data
We employ appropriate security measures to help protect your Personal Information and guard against access by unauthorised persons. All information stored on our recruitment software is secured through the Microsoft Azure Infrastructure and located at two data centres locations within Europe. Our primary centre is located in Microsoft’s Western European centre, and these facilities are secured by a series of measures, including (but not limited to) biometric access, security alarm systems and round-the-clock security staff.
Hard copy information is stored in secure locked storage. We may also use commercial-grade cloud storage (Dropbox Business) to store personal data relating to you. Dropbox is fully GDPR compliant.
We do not sell, rent, distribute or otherwise make Personal Information commercially available to any third party.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.
We do the following to try to ensure our data is accurate:
· Prior to making an introduction we 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.
Your rights
You may withdraw your consent at any time. It is important to us that you are in control of your own information. As a result, we offer the following controls:
You may request access to or copies of the Personal Information that we hold about you. If you would like to exercise this right, please contact us at gdpr@orangeappointments.com or the address above.
If you believe that any information we have about you is incorrect or incomplete, please contact us at gdpr@orangeappointments.com as soon as possible. We will take steps to seek to correct or update any information if we are satisfied that the information we hold is inaccurate. You may request that we restrict our processing;
You may request that your Personal Information be deleted, where it is no longer necessary for the purposes for which it is being processed and provided there is no other lawful basis for which we may continue to process such information;
To the extent we are processing your Personal Information to meet our legitimate interests (as set out above), you may object to the processing of your Personal Information by us. If we are unable to demonstrate our legitimate grounds for that processing, we will no longer process your Personal Information for those purposes;
You may object to our processing as set out above;
You may withdraw any consent given to processing.
The GDPR provides you with the following rights. To:
· Request correction of the personal information that we hold about you. This enables you 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 in certain formats, if practicable.
· 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 link: https://ico.org.uk/concerns/
Access to information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force).
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Contact
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to: gdpr@orangeappointments.com