Changes to legislation
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) replaces the Data Protection Regulation (Directive 95/46/EC) from 25 May 2018. 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. Your new rights under the GDPR are set out in this notice and will apply once the GDPR becomes law on 25th May 2018. Who are Butler Ross Limited and what do we do? Butler Ross Limited are a recruitment agency and recruitment business as defined in the Employment Agencies Act 2003. We collect the personal data of the following types of people to allow us to undertake our business;
- Prospective and placed candidates for permanent or temporary roles;
- Prospective and live client contacts;
- Supplier contacts to support our services;
- Employees, consultants, temporary workers;
In doing so we act as a Data Controller
What is personal data?
Personal data is data that can identify you as a living individual. There is general personal data such as name, address, national insurance number and online identifiers/location data. There is also sensitive personal data which includes information on physical and mental health, sexual orientation, race or ethnic origin, religious beliefs, trade union membership and criminal records. Sensitive personal data must be protected to a higher level.
How we collect your data
You may have applied directly to us or we may have found your details from a jobs board or social networking site. We are able to process your data if we have a legal basis for doing so. There are six legal bases for processing data but we will rely on:
- Your consent to send direct marketing messages about services other than our recruitment services
- That the processing is necessary for the performance of a contract with you
- That we have a legitimate interest in processing your personal data.
We collect information about you to carry out our core business and ancillary activities.
Why we process your personal data & our legal justification. We believe that we have a legitimate interest in processing your data for the purposes of providing work seeking services.
We believe that it is reasonable to expect that if you are looking for employment or have posted your CV onto a job board or networking site, you are happy for us to collect and use your data to offer or provide you with work seeking services. This can include forwarding your details to prospective employers or matching your details against our open vacancies. Prospective employers might want to verify certain aspects such as references and qualifications. We need to be able to do this to function as a profit-making organisation.
We have to comply with various legal, regulatory and tax obligations and we have a legitimate business interest in doing so. Therefore we may share your data with the appropriate authorities to meet these obligations.
To ensure we can provide services to you we will need to use your data for internal processes such as payroll or invoicing.
We want to help you find a job. We believe that sending you job recommendations and relevant market intelligence will facilitate this. We will process your data to send you the appropriate content.
To ensure that we can provide you and your organisation with the best possible service we store details of the organisation and its contacts as well as notes of conversations, emails, meetings and previous jobs and recruitment activity. We believe that this falls within our legitimate interest in providing recruitment services to you.
In certain cases, such as processing sensitive data, we will need to obtain your consent. In these cases:
- You have to give your consent freely
- You have to know what you are consenting to
- You should be able to control your consent
- We will keep a record of your consent
- You have the right to withdraw your consent
What data do we collect?
During the course of providing you with work seeking services we may collect some or all of the following types of personal data. The reason we do this is to enable us to provide the best service we can to help you find your next job. The following list is not exhaustive and is in addition to any data that we are required by law to process:
- Contact details
- Date of birth
- Employment history
- Immigration status
- Copy of passport / ID card / other form of identification
- Tax information such as social security numbers
- Details of criminal convictions where applicable to the role
- Current salary and package
- Any further information that you tell us included in future employment preferences
- Dates that you make contact with our organisation
We will collect data that will help us ensure that the relationship between our organisations runs as smoothly as
possible. This will normally be restricted to name, telephone number and email address of individual contacts.
How will we use your data?
- The processing of your personal information may include:
- Collecting and storing your personal data, whether in manual or electronic files
- Notifying you of potential roles or opportunities
- Assessing and reviewing your suitability for job roles
- Introducing and/or supplying you to actual or potential Clients
- Engaging you for a role with us or with our Clients, including any related administration e.g. timesheets and payroll
- Collating market or sector specific information and providing the same to our Clients
- Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment Services
- Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers
- To market our Recruitment Services
- Retaining a record of our dealings
- Establishing quality, training and compliance with our obligations and best practice
- For the purposes of backing up information on our computer systems
We use your data for a number of purposes:
1) Recruitment Services
Our primary function is to provide you recruitment services including presenting you with candidates; providing
market intelligence such as salary surveys; and the provision of recruitment process outsourcing services. To enable
us to provide these services we will process your data in the following ways:
- Storing your data on our database so we can contact you in relation to recruitment activities
- Recording notes of conversations and meetings
- For targeted marketing campaigns
- Customer satisfaction surveys
2) Marketing Activities
As a matter of course we shall not seek your consent when sending marketing materials to corporate email
addresses. If you wish to opt out of receiving marketing information you can unsubscribe from receiving them at any
Who we share your personal data with?
We shall not share your personal information unless we are entitled to do so. The categories of persons with whom
we may share your personal information include:
- Individuals, hirers and other third parties, necessary for the provision of our Recruitment Services
- Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
- Parties who process data on our behalf include:
- IT support
- Payroll support
- Storage service providers including cloud
- Background screening providers
- Legal and professional advisers
- Job boards and job aggregators, where it helps us find you work
- Managed Service Providers where our clients have outsourced their recruitment process
- Third party IT companies with whom we are contracted to and have appropriate processing agreements
- Third party services providers who perform work on our behalf (e.g. auditors, lawyers, IT providers etc.)
- Tax and local authorities to enable us to comply with laws and regulations
- Marketing technology providers
What are your rights?
We take the protection of your personal data very seriously and it is important that you know your rights within that
context, which include:
- The right to be informed about the personal data that we process on you;
- The right of access to the personal data that we process on you;
- The right to rectification of your personal data;
- The right to erasure of your personal data in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on a public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
Where you have consented to us processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting our Data Controller Russell Soan at email@example.com
Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken to both evidence our compliance, and to take steps to minimise the prospect of any data being processed in the future should it be received again from a third-party source.
If you have any questions concerning your rights or should you wish to exercise any of these rights please contact: firstname.lastname@example.org
How long will we keep your information for?
At Butler Ross, we understand our legal duty to retain accurate data. To ensure data is updated regularly, we have implemented strict business policies, including regular data compliance audits and routines to remove all outdated data. Where data is outdated, with no reasonable or accurate way to update the data, it will be deleted from all Butler Ross sources. It may be necessary under legal, contractual or legitimate business interests for Butler Ross to keep a copy of this information on our systems for a prolonged period. Once this data is deemed no longer necessary to store under legal, contractual or legitimate business interests, it will be deleted from all Butler Ross sources.
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website, which enables the website to tailor its offerings to your preferences when you visit it.
- Make our website work as you'd expect
- Remember your settings during and between visits
- Improve the speed/security of the site
- Monitor user traffic patterns
- Understand how our visitors use our website
- Make our marketing more efficient
What all of this means is that you get the best possible user experience and the most relevant information based on your needs. Cookies enable us to constantly evolve, develop and improve functionality to provide you with the best possible user experience.
The cookies we use:
- Strictly necessary - Essential cookies to enable you to use the site effectively i.e. applying for a job or submitting a CV. Accepting these cookies is a condition of using the site:
- Functionality - These cookies help our site remember the choices you made, for example, username, and also help make the most of our enhanced features, such as providing news or updates relevant to you.
- Performance - These cookies help us monitor the performance of our site, providing us with the information to constantly optimise and develop our site to get the best user experience for you, for example site visits or source of visitors.
- Personalisation - We use personalisation cookies to make sure we advertise the jobs that we think may be of interest to you, making your user experience a personalised one.
- Third party - As you use our site, you will notice that we have content from other sites. We also facilitate the opportunity to engage with us further through social media channels. We use third-party cookies to help deliver relevant information to you and integrate content with social networks.
- Google Analytics - These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
so remember to check your browsers ‘help’ settings.
How we safeguard your personal data
We take all reasonable steps to ensure that your data is safe and protected from misuse, loss or unauthorised access. We ensure this by implementing a range of technical safeguards and operational processes. We also have processes to deal with any suspected data breach. If you suspect that your data has been misused, or has been compromised please contact us immediately at email@example.com
If you are dissatisfied about any aspect of the way in which your data is processed you may, in the first instance refer the matter to: firstname.lastname@example.org. This does not affect your right to make a complaint to the Information. Commissioner’s Office: https://ico.org.uk
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to a member of our data protection team:
Phone: 01962 896939
FAO Data Protection Department
Butler Ross Limited
37/39 Southgate Street