Privacy Policy

Introduction

Our Privacy Policy explains what we do with your personal data, whether we are helping you find a job, continuing a relationship, providing you a service, receiving a service, using your data to ask for your assistance in relation to one of our candidates, or you are visiting our website. It explains how we collect and process your personal data, and how, in doing so, we comply with our legal obligations to you.

It is important to remember that the law changes and evolves and we may need to amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date.

If you should have any questions in relation to our privacy policy; the person responsible for your personal data is; Christopher Tuthill (Operations Manager) who can be contacted on 01895 520 700.

Please be aware that both our trading names of Uxbridge Employment Agency and Windsor Employment Agency operate under our legal entity; Top Flight Recruitment Ltd (company registration 01367823) and throughout will be referred to as TFR.

Our “Keep it Simple” Section

What personal data do we collect?

• Candidate Data: In order to provide employment opportunities to you we need to process certain information. We only ask for details that help us help you, such as your name, address, telephone number, education details, employment history, emergency contacts, immigration status, financial information (if you are temping with us), and relevant tax information such as NI numbers (and of course you may choose to share other relevant information with us). Where appropriate and in accordance with local laws, we may also collect information related to your health, diversity information or details of any criminal convictions.
• Client Data: If you are a client of ours it’s our job to find the right candidate for your business! To do this we need to collect certain information about you, or individuals at your organisation, in the course of providing you our service such as: finding candidates who are the right fit for you or your organisation; and/or notifying you of content published by TFR which is likely to be relevant and useful to you (for example our Jobs Outlook of availability updates).
• Supplier Data: We don’t need a lot of data from our suppliers, but we do need some to ensure we can pay our bills. We need things like contact details so we can communicate with you. We also need other information such as bank details so that we can pay for the services you provide.
• Individuals whose data we received from staff and candidates – such as emergency contact details and reference requests: As part of our service to provide candidates with employment opportunities we need to ensure this is done safely and securely – to do this we need some basic background information. We only ask for the most basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our staff members of candidates.
• Website Users: We are not a global multinational juggernaut so rest assured that we only collect a very limited amount of data from our website users. This is in the main to monitor how many “hits” we get to our site and includes information such as how someone uses our website, the frequency with which someone accesses our website and what time our website is proving most popular.

It’s important at this point to remember that some elements of the personal data we collect from you is required to enable us to fulfil our contractual duties i.e. candidates' NI numbers are required for payroll purposes. Other items may simply be needed to ensure that our relationship can run smoothly.

As part of our work finding services it is important to remember at certain points we will need to share certain details about you to fulfil our service. Should you decline to provide us with such data, we may not be able to provide you with our services or, in some cases, may not be able to continue with our relationship.

If you would like a more detailed description of any of the above types of data we collect about you, please review our “The Specifics”Section.

How do we collect personal data?

• Candidate Data: There are two main ways in which we collect your personal data:
  • Directly from you; and
  • From third parties.
• Client Data: There are two main ways in which we collect your personal data:
  • Directly from you; and
  • From third parties (e.g. our candidates) and from other sources (e.g. social media).
• Supplier Data: We collect your personal data during the course of our work with you.
• Individuals whose data we received from staff and candidates – such as emergency contact details and reference requests: Your contact details are collected when a staff member or candidate puts your name down as their emergency contact or where a candidate gives them to us in order for you to serve as a referee.
• Website Users: Data on visitors to our website is collected automatically via cookies, in line with cookie settings in your browser.

If you want to know more about how we collect your personal data, please review our “The Specifics”Section.

How do we use personal data?

• Candidate Data: Our role is to find you find employment so the main reason for using your personal data is to help you find your ideal role! The more we understand about you, your skillset and your ambitions, the more targeted we can tailor our service. Also, certain types of data are required in accordance with the law i.e. if we are pay rolling a temporary worker we need to report to HMRC that we are taking tax deductions etc. We may also use your personal data for things like marketing, profiling and diversity monitoring. If it’s appropriate in these instances we will seek your consent to undertake some of these activities.
• Client Data: Presumably you are using our services to find that special candidate that will fit right into your team! To achieve this we need certain details to ensure that the contractual arrangements between us can be implemented and so that our relationship runs smoothly. As with candidates, the more we understand about you, your requirements and your companies ethos, the more targeted we can tailor our service.
• Supplier Data: Limiting ourselves to very specific data on suppliers we still need certain personal data are to ensure that the contractual arrangements between us can properly be implemented so that our relationship runs smoothly (and to comply with legal requirements).
• Individuals whose data we received from staff and candidates – such as emergency contact details and reference requests: In the process of offering our services it is vital we are able to verify their details and qualifications given to us so we can match the ideal candidate with prospective employers. For this a referees’ personal data is used to contact them to secure this information. Also, we use the personal details of emergency contacts in the case of an accident or emergency.
• Website Users: We use your data to monitor the performance of our website and to receive applications to suitable opportunities.
• Please note that communications to and from Top Flight Recruitment staff including emails may be reviewed as part of internal or external investigations or litigation.

Who do we share personal data with?

• Candidate Data: Our main function is to share your information with prospective employers to increase the chances of securing the job you seek. Unless you say otherwise, we may also need to share your information with associated third parties such as our clients Managed Service Providers to get your details across to them for review. Also, if you are looking to temp through us we are required by law to collect pensions past a qualifying period and from then would be required to share your data with our nominated pension’s provider.
• Client Data: If you want that special candidate we are going to have to share some details on who you are and what the job is all about! For this reason we share your data to make sure we can provide you with a suitable pool of candidates. Unless you say otherwise, we may share your information with any of our group companies and associated third parties such as our service providers to help us meet these aims.
• Supplier Data: Unless you specify otherwise, we may share your information with associated third parties such as our service providers and organisations to whom we provide services.
• Individuals whose data we received from staff and candidates – such as emergency contact details and reference requests: Unless you say otherwise, we may share your information with associated third parties such as our service providers and organisations to whom we provide services.

If you would like to see a list of who we may share your personal data with, please review our “The Specifics”Section.

How do we safeguard your personal data?

• TFR is committed to protecting your personal data. That's why we have such things as this privacy policy to make things clear and transparent. We have yet to suffer a single data breach and have processes in place to prevent unauthorised access to, and misuse of, your personal data.
• For more information on the procedures we put in place, please review our “The Specifics”Section.

How long do we keep your personal data for?

• Unless we are required by law to preserve your data (i.e. because of payroll and tax records etc.) if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of six years, we will delete your personal data from our system. 

What are your rights

• We may hold your personal data, but you still have rights in relation to it. To get in touch about these, please contact us on 01895 520 700 and ask to speak to Chris Tuthill. We will aim to deal with your request without unnecessary delay. It is worth noting that we may be required to keep a record of your contact to help us resolve your request.
• Right to object: We will be using your data because it necessary for our legitimate interests to do so (and we feel it offers no detrimental effect for you), however if you do not agree, you have the right to object. Our aim is then to respond to your objection within 30 days (however, this may have to be extended in certain cases).
• Right to withdraw consent: If we have acquired your consent to process your data (for example, on formal registration at our offices), you have the right to withdraw your consent at any time.
• Data Subject Access Requests (DSAR): We want to be as transparent as possible and at any time you have the right to ask us to confirm the information we hold about you. It’s your data so you may ask us to modify, update or delete such information. If we receive such a request we will action in one of the following ways;
  • we will usually ask you to verify who you are (to ensure it is you we are speaking to), or ask for further information about your request; and
  • where we are legally required to do so, we may decline your request, but we will explain the reasons why we are doing so.
• Right to erasure: You also have the right to request erasure from our systems. If we received such a request we will respond within 30 days (however, this may have to be extended in certain cases) and will only be unable to process such a request if certain conditions apply. If we do agree, your data will be deleted but we will generally assume that you would prefer us to keep a note of your name on a list of individuals who do not want to be contacted to minimise the chances of one of our staff contacting you in the future (otherwise we would have no reminder that you did not want to be contacted!). If you object to this you are free to say so but please be aware that we might inadvertently contact you again as we would have no record of your previous requests.
• Right of data portability: Although more applicable to banks or telephony providers; your do have the right to transfer your data from us to another company. We will do our best to help with this and will transfer your data to you by providing electronic copies of CV’s etc. we have on our system. 
• Right to lodge a complaint with a supervisory authority: If you feel we are not complying with the spirit of data protection you also have the right to lodge a complaint with the Information Commissioners Office (ICO), details of which can be found in our “The Specifics”Section.

Who is responsible for processing your personal data on our website?

• You will be pleased to hear we, TFR, controls the processing of your personal data on our website.
• If you've got any further questions, or want further details, please review our “The Specifics”Section.

“The Specifics”Section

What kind of personal information do we collect?

If you are reading this then are looking for more detail on what we collect about you – fair enough, here's a more detailed look at the information we may collect. Please bear in mind that the information described below is in addition to any data we are required to collect by law;

• Candidate Data: Depending on the circumstance, law and requirements we may collect some or all of the information listed below to allow us to offer you our work finding services:
  • Name;
  • Date of birth;
  • Sex/gender;
  • Photograph;
  • Marital status;
  • Contact details;
  • Education details;
  • Employment history;
  • Emergency contacts and details of any dependants;
  • Referee details;
  • Immigration status (whether you need a work permit);
  • Nationality/citizenship/place of birth;
  • A copy of your driving licence and/or passport/identity card;
  • Financial information (where we need to carry out financial background checks);
  • NI numbers and any other tax-related information;
  • Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information;
  • Details of any criminal convictions if this is required for a role that you are interested in applying for;
  • Details about your current remuneration, pensions and benefits arrangements;
  • Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website;
  • Extra information that you choose to tell us;
  • Extra information that your referees chooses to tell us about you;
  • Extra information that our clients may tell us about you, or that we find from other third party sources such as job sites;
  • IP address;
  • The dates, times and frequency with which you access our services; and
  • CCTV footage if you attend our premises.
• Please remember that the above list of personal data is not exhaustive.
• Client Data: It’s fair to say that we collect a lot less data on our clients. We really only need your contact details (or the details of individual contacts at your organisation) such as names, telephone numbers and email addresses to enable us to contact you and offer our services. We may also hold additional information that an individual in your organisation has chosen to tell us. If we need any additional personal data for any reason, we will let you know.
• Supplier Data: As with clients we don’t really collect much data about suppliers. Again, we will need basic details of contacts within your organisation and details like telephone numbers and email addresses. We do also collect bank details in this scenario so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us. If we need any additional personal data for any reason, we will let you know.
• Individuals whose data we received from staff and candidates – such as emergency contact details and reference requests: All we need from a referee is information on what you already know about a candidate. Emergency contact details give TFR details on somebody to call on in an actual emergency. To ask for a reference, we'll need the referee's contact details (name, email address and telephone number). We' will also need these details if our candidate or a member of our staff has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.
• Website Users: We collect a limited amount of data which includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular. 

How do we collect personal data?

• Candidate Data: is collected in three primary ways:
  • Personal data that you give to us;
  • Personal data that we receive from other sources; and
  • Personal data that we collect automatically.
• Personal data you give to us
  • We need to know certain information about you in order to provide our service. This enables us to provide you with relevant opportunities and hopefully should save you time in not having to trawl through opportunities that are not relevant
  • There are various ways you can share your data with us. These may include;
    • Applying via our website or by an application form, as part of registering at our offices;
    • Handing in a hard copy CV at our office, a recruitment event, or job fair;
    • Emailing your CV to a TFR consultant or being interviewed by them;
    • Applying for jobs through a job board, which then forwards you to our website; or
    • Entering our website through a social media channel such as Facebook or Twitter.
• Personal data we receive from other sources
  • We may also receive personal data about you from other sources. Depending on the circumstance these may include personal data received in the following situations:
    • Your referees may disclose personal information about you;
    • Our clients may share personal information about you with us;
    • We may obtain information about you from searching for potential candidates from third party sources, such as job sites;
    • When you 'like' our page on Facebook or 'follow' us on Twitter we will receive your personal information from those sites; and
    • If you were referred to us through an RPO or an MSP supplier, they may share personal information about you with us.
• Personal data we collect automatically
  • To the extent that you access our website or read or click on an email from us we may also collect your data automatically or through you providing it to us. 
• Client Data: We collect client personal data in three ways:
  • Personal data that we receive directly from you;
  • Personal data that we receive from other sources; and
  • Personal data that we collect automatically.
• Personal data that we receive directly from you
  • Hopefully we both share the same goal - to make sure that you have the best possible team within your organisation! We mainly receive data from you in two ways:
    • Where you contact us, usually by phone or email; and/or
    • Where we contact you, either by phone or email.
• Personal data we receive from other sources
  • Where appropriate and in accordance local laws and requirements, we may seek more information about you or your colleagues from other sources including:
    • From other limited sources and third parties (for example from our candidates to the extent that they provide us with your details to act as a referee for them).
• Personal data we collect via our website
  • To the extent that you access our website or read or click on an email from us we may also collect your data automatically or through you providing it to us.
• Website Users: When you visit our website there is certain information that we may automatically collect, whether or not you decide to use us. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content. We collect your data automatically via cookies, in line with cookie settings in your browser.

How do we use your personal data?

Right, having now obtained the data about you what then are we doing with it? Well, we use your data in a number of ways;

• Candidate Data: We mostly use Candidate data in four ways:
  • Our Recruitment Activities;
  • For Marketing Purposes;
  • Equal Opportunities Monitoring; and
  • Where needed, to help us to establish, exercise or defend legal claims.

• Recruitment Activities
  • For an employment agency our main area of work is recruitment – specifically connecting the right candidate with the right job. We've included below various ways in which we may use your personal data for this purpose, however recruitment is quite a fluid activity so please bear in mind this list is not exhaustive;
    • Sourcing your data from you and sources such as LinkedIn;
    • Storing of your personal details so we can contact you;
    • By providing you with our services to facilitate the recruitment process;
    • Comparing data about you against vacancies which we consider to be suitable;
    • Sending your information to clients to access your eligibility for a job;
    • Carrying out our legal and compliance obligations arising from any contracts entered into between us;
    • Carrying out our obligations arising from any contracts entered into between TFR and third parties in relation to your recruitment;
    • Facilitating our payroll and invoicing processes;
    • Requesting customer satisfaction surveys;
    • Verifying details you have provided to us, using third party resources (such as skills tests), or to request information (such as references, qualifications and where applicable any criminal convictions;
    • Complying with our legal obligations in connection with the detection of crime or the collection of taxes; and
    • Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.
• We may use your personal data for the above purposes if we deem it necessary to do so, please read Our Legal Bases for Processing Your Data – Legitimate Interests for more information.
• If you are not happy about this you do have the right to object and can find out more about how and when to do so in our Right to Object section. 
• Marketing Activities
  • We are in the business of communication and as such we may periodically send you information that we think you may find interesting. In particular, we may wish to use your data for the purposes listed below, however please note that this list is not exhaustive. To:
    • market our full range of recruitment services (permanent, temporary, contract) to you;
    • send you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you;
    • display promotional excerpts from your details on TFR website(s) as a success story (only where we obtained your consent).
  • In some scenarios we may need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we'll ask for this via an opt-in or soft-opt-in (explained below).
  • Soft opt-in consent is a type of consent which applies where you have previously engaged with us (for example by previously submitting a job to us), and we are marketing our services. Under ‘soft opt-in’ consent, we will take your consent as given unless you choose to opt out. We find for most people this is very beneficial as we can do things like suggest jobs that may be suitable to you alongside the specific one you applied for. This is a real benefit as it significantly increasing the likelihood of us finding you your ideal role.
  • If you are unhappy in our approach to marketing then you have the right to withdraw your consent at any time and can find out more about how to do so by reading our Right to Withdraw Consent section. Although we try our hardest to get things right most of the time, we’re not perfect and we want to be clear that even though you may have opted out from our marketing communications it is possible that your details may be recaptured through public sources in an unconnected campaign. We always try to ensure this doesn't happen, but if it does, we apologise. In this circumstance just please opt out again (unsubscribe). 
• Equal opportunities monitoring and other sensitive personal data
  • TFR are committed to ensuring that our processes are aligned to both privacy and our approach to equal opportunities. Some of the data we may collect comes under the umbrella of "diversity information". This could be information about your ethnic background, gender, disability, age, religion or other similar beliefs, and/or social-economic background. Where appropriate we use this information (on an anonymised basis) to monitor our compliance with our equal opportunities policy. We may also disclose this (again, anonymised) data to clients where this is contractually required or the client specifically requests such information to enable them to comply with their own processes.
  • This information is called ‘sensitive’ personal information and comes under slightly stricter data protection rules. If we therefore ask to obtain this information from you we will require your explicit consent before we can use it. This is done by asking for a clearly written “opt-in” telling us that you agree to us collecting and using this information.
  • We may collect other sensitive personal data about you, such as criminal convictions if this is appropriate and is required for a role that you are interested in applying for. We will never do this without your consent.
  • If you are not happy about any of the above you have the right to withdraw your consent at any time and you can find out how to do so by reading our Right to Withdraw Consent section.
• To help us to establish, exercise or defend legal claims
  • Although we will do everything to avoid the requirement for a legal claim we do acknowledge that In unusual circumstances, we may use your personal data to help us to establish, exercise or defend a legal claim.
• Client Data: We use client information for:
  • Our Recruitment Activities;
  • For Marketing Purposes; and
  • Where needed, to help us to establish, exercise or defend legal claims.
  • Here are some more details about each:
    • Recruitment Activities
      • For an employment agency our main area of work is recruitment – specifically connecting the right candidate with your opportunity. We've included below various ways in which we may use your personal data for this purpose, however recruitment is quite a fluid activity so please bear in mind this list is not exhaustive;
        • Storing your details on our company database so that we can contact you;
        • Keeping records of any conversations and meetings, so that we tailor our services to you;
        • Requesting customer satisfaction surveys; and
        • Processing your data for the purpose of targeted marketing campaigns for locally available talent.
      • We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to know more about what this means, please read Our Legal Bases for Processing Your Data – Legitimate Interests for more information.
      • If you are not happy about this you do have the right to object and can find out more about how and when to do so in our Right to Object section.
• Marketing Activities
  • Subject to laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials such as our Jobs Outlook or Availability Updates to a business postal or email address.
  • If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so by reading our Right to Withdraw Consent section.
• To help us to establish, exercise or defend legal claims
  • Although we will do everything to avoid the requirement for a legal claim we do acknowledge that In unusual circumstances, we may use your personal data to help us to establish, exercise or defend a legal claim.
• Supplier Data:
  • We know, we know, you are busy and don’t want us contacting you all the time. For this reason we will only use your information:
    • To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;
    • To offer services to you or to obtain support and services from you;
    • To perform certain legal obligations;
    • To help us to target appropriate marketing campaigns; and
    • In more unusual circumstances, to help us to establish, exercise or defend legal claims.
  • We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you want to know more about what this means, please read Our Legal Bases for Processing Your Data – Legitimate Interests for more information.
  • Subject to laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials such as our Jobs Outlook or Availability Updates to a business postal or email address.
  • If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so by reading our Right to Withdraw Consent section.
• Individuals whose data we received from staff and candidates – such as emergency contact details and reference requests:
  • We only use the information that candidates gives us about you for the following purposes:
    • If you are named as an emergency contact, we will contact you in the event of an accident or emergency affecting them; or
    • If you were named as a referee, we will contact you in order to complete the reference request process. This is an important check in our candidate quality assurance process, and could be the difference between the individual getting a job or not.
    • If you were named as a referee, we may sometimes use your details to contact you in relation to recruitment activities in general in which case we will use your data for the same purposes for which we use the data of clients. If you would like to find out more about what this means, please review our Client Data section.
  • We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you want to know more about what this means, please read Our Legal Bases for Processing Your Data – Legitimate Interests for more information.
  • Subject to laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials such as our Jobs Outlook or Availability Updates to a business postal or email address.
• Website Users: We use your data to help us monitor the effectiveness and traffic to our website. 

Who do we share your personal data with?

• Where required and in accordance with the law and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:
  • Individuals and organisations whom hold information related to your reference or application form (such as current, past employers, educators and examining bodies and employment and recruitment agencies);
  • Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
  • Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
  • Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
  • Marketing technology platforms and suppliers;
  • In the case of candidates: potential employers and other recruitment agencies/organisations to increase your chances of finding employment;
  • In the case of candidates: third party partners, job boards and job aggregators where we consider this will improve the chances of finding you the right job;
  • In the case of candidates: MSP suppliers as part of our clients' MSP programmes;
  • In the case of candidates and our candidates' and prospective members of staff's referees: third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws.

How do we safeguard your personal data?

• We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
• If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately by contacting our Operations Manager, Chris Tuthill on 01895 520 700.

How long do we keep personal data for?

• Unless we are required by law to preserve your data (i.e. because of payroll and tax records etc.) if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of six years, we will delete your personal data from our system.
• "Meaningful contact" to us means, for example communication between us (either verbal or written), or where you are engaging with our services.

How can you access, amend or take back the personal data that you have given to us?

• We have interpreted one of GDPR's main objectives as to protecting the rights of EU citizens and individuals in the EU in regards to your data privacy. This means that you have various rights in respect of your data, even once you have given it to us. These are described in more detail below.
• To get in touch about these rights, please contact Chris Tuthill on 01895 520 700. We will seek to deal with your request within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
• Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
• The "legitimate interests" and "direct marketing" categories above are the ones most likely to apply to our Website Users, Candidates, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
  • we can show that we have compelling legitimate grounds for processing which overrides your interests; or
  • we are processing your data for the establishment, exercise or defence of a legal claim.
• If your objection relates to direct marketing, we must act on your objection by ceasing this activity. 
• Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, on formal registration in our offices) you may withdraw this consent at any time and we will cease to carry out the activity that you previously consented to unless there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
• Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. In this instance we may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive" i.e. you request the same action several times. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
• Right to erasure: You have the right to request that we delete your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
  • the data are no longer necessary for the purpose for which we originally collected and/or processed them;
  • where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
  • the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
  • it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
  • if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
  • We would only be entitled to refuse to comply with your request for one of the following reasons:
    • to exercise the right of freedom of expression and information;
    • to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
    • for public health reasons in the public interest;
    • for archival, research or statistical purposes; or
    • to exercise or defend a legal claim.
  • When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
• Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
  • The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
    • where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
    • where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
    • where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
    • where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
  • If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
• Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
• Right of data portability: If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your Top Flight Recruitment details to another provider. To allow you to do so, we will provide you directly with your data.
• Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority.
  • If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please contact Chris Tuthill on 01895 520 700. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
  • It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.

Who is responsible for processing your personal data on our website?

• The person responsible for your personal data is; Christopher Tuthill (Operations Manager).
• If you have any comments or suggestions concerning this Privacy Policy please contact Chris on 01895 520 700.

How do we store and transfer your data internationally?

• In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data may be transferred:
  • to third parties (such as advisers or other Suppliers to the Top Flight Recruitment business);
  • to overseas clients;
  • to clients within your country who may, in turn, transfer your data internationally;
  • to a cloud-based storage provider; and
  • to other third parties, identified in our Who do we share your personal data with section.
• We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
  • by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
  • transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or
  • where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a client of ours); or
  • where you have consented to the data transfer.
• To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.
• Our Legal Bases for Processing Your Data
  Legitimate Interests Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."
  • We don't think that any of the following activities prejudice individuals in any way –in fact, they help us to offer you a more tailored, efficient service, so everyone's a winner! However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please read our Right to Object section.
  • Candidate Data:
    • We think it's reasonable to expect that if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our bank of vacancies. Once it's looking like you may get the job, your prospective employer may also want to double check any information you've given us (such as skills tests) or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws. We need to do these things so that we can function as a profit-making business, and to help you and other candidates get the jobs you deserve.
    • We want to provide you with tailored job recommendations and relevant articles to read to help you on your job hunt. We therefore think it's reasonable for us to process your data to make sure that we send you the most appropriate content.
    • We have to make sure our business runs smoothly, so that we can carry on providing services to candidates like you. We therefore also need to use your data for our internal administrative activities, like payroll and invoicing where relevant.
    • We have our own obligations under the law, which it is a legitimate interest of ours to insist on meeting! If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.
  • Client Data:
    • To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.
  • Supplier Data:
    • We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.
  • Individuals whose data we received from staff and candidates – such as emergency contact details and reference requests:
    • If you have been put down by a candidate or a prospective member of staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.
    • If a candidate or staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.

Consent

• In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
• Article 4(11) of the GDPR states that (opt-in) consent is "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her." In plain language, this means that:
  • you have to give us your consent freely, without us putting you under any type of pressure;
  • you have to know what you are consenting to – so we'll make sure we give you enough information;
  • you should have control over which processing activities you consent to and which you don’t. We provide these finer controls within our privacy preference centre; and
  • you need to take positive and affirmative action in giving us your consent – we're likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
• We will keep records of the consents that you have given in this way.
• We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the recruitment services we provide as long as you do not actively opt-out from these communications.
• As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be read in our Right to Withdraw Consent section.

Establishing, exercising or defending legal claims

• Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity".
• This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

How to contact us

The person responsible for processing the personal data of Website Users is:

Christopher Tuthill – Operations Manager.
Tel: 01895 520 700
Email:  

Please feel free contacting us if any of the following is required:

• to access, amend or take back the personal data that you have given to us;
• if you suspect any misuse or loss of or unauthorised access to your personal information;
• to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data);
• with any comments or suggestions concerning this Privacy Policy

How to contact your local supervisory authority

If you wish to contact your local supervisory authority, The Information Commissioner's Office (ICO), you can contact them in the following ways:

• Phone: 0303 123 1113
• Email:
• Post:
  Information Commissioner's Office
  Wycliffe House
  Water Lane
  Wilmslow
  Cheshire
  SK9 5AF

GLOSSARY

• Candidates – includes applicants for all roles advertised or promoted by TFR, including permanent, part-time and temporary positions and freelance roles with TFR’s clients; as well as people who have supplied a speculative CV to us not in relation to a specific job. Individual contractors, freelance workers and employees of suppliers or other third parties put forward for roles with TFR, clients as part of an MSP offering or otherwise will be treated as candidates for the purposes of this Privacy Policy.
• Clients - while it speaks for itself, this category covers our customers, clients, and others to whom TFR provides services in the course of its business.
• Delete – while we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or staff.
• General Data Protection Regulation (GDPR) – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.
• Managed Service Provider (MSP) programmes – clients' outsourcing of the management of external staff (including freelance workers, independent contractors and temporary employees) to an external recruitment provider.
• Other people whom TFR may contact – these may include candidates' and TFR staff emergency contacts and referees. We will only contact them in appropriate circumstances.
• Staff – includes employees and interns engaged directly in the business of TFR (or who have accepted an offer to be engaged) as well as certain other workers engaged in the business of providing services to TFR (even though they are not classed as employees). For these purposes we also include employees of TFR who are engaged to work on clients' premises under the terms of RPO or MSP agreements. To be clear, 'Staff' does not include individuals hired by TFR for the purpose of being placed with clients outside of an MSP arrangement. These individuals are treated in the same way as TFR Candidates and are covered by this Privacy Policy. Likewise, independent contractors and consultants performing services for TFR fall within the definition of a 'Supplier' for the purposes of this Privacy Policy.
• Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to TFR. In certain circumstances TFR will sub-contract the services it provides to clients to third party suppliers who perform services on TFR’s behalf. In this context, suppliers that are individual contractors, freelance workers, or employees of suppliers will be treated as candidates for data protection purposes. Please note that in this context, TFR requires Suppliers to communicate the relevant parts of this Privacy Policy (namely the sections directed at Candidates) to their employees.
• Website Users - any individual who accesses any of the TFR websites.