At Flagstaff Consultants Ltd (”We”) are committed to protecting and respecting your privacy. Whether you deal with us as a candidate, client or partner we will always make sure we do the right thing. This means operating honestly and transparently, that includes the correct handling of your data.
This policy 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 policy but will only apply once the GDPR becomes law on 25th May 2018.
For the purposes of data protection legislation in force from time to time the data controller is Flagstaff Consultants Ltd of Tower Point 5th Floor, Platf9rm, 44 North Road, Brighton, England, BN1 1YR.
Who we are and what we do
We are a recruitment agency as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). Given the nature of what we do on behalf of our candidates and clients we have collect personal data of the following stakeholder groups to ensure we can deliver (when you see the examples below things will make a bit more sense):
Prospective and placed candidates for permanent or contract roles (so we can help them find work)
Prospective and live client contacts (so we can keep in touch throughout the recruitment process and once the candidate has started)
Supplier contacts to support our services (so we can pay our suppliers and keep them as part of our team)
Employees, consultants, temporary workers (so we can keep our staff happy and do the right things by them)
If we collect information about you it will be in order to carry out our core business and ancillary activities.
Information you give to us or we collect about you
This is information about you that you give us by filling in forms on our website www.flagstaffconsultants.com (website) or by corresponding with us by phone, video calls, e-mail, personal meetings or otherwise. It includes information you provide when you register to use our website, to enter our database, subscribe to our services, attend our events, enter a promotion or survey, and when you report a problem with our site.
The information you give us or we collect about you may include your name, address, company name, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the relevant country, identification documents, curriculum vitae and photograph, emergency information, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
Information we collect about you when you visit our website
With regard to each of your visits to our site we will automatically collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer or mobile device to the Internet, browser type and version, and if you choose to share it, your location data. We do this to improve your experience on our website and where relevant direct you to the appropriate sub directory of our site for your specific geography. The net result should be that you are able to either find jobs easier or get a better understanding of whether we are the right recruitment partner for you or your company.
We will also store information about your visit, including referral information (should you choose to share it), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), along with any personally identifiable information you leave on our contact forms. We keep this information to ensure that the context of our communication with you as relevant as possible. You don’t have to give us any of this data if you do not wish to.
Information we obtain from other sources
We also obtain information about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, other social media and personal recommendations. In this case we will contact you within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are also working closely with third parties including business partners, such as umbrella companies, from whom we may receive information about you for the purposes of our recruitment services and ancillary support services.
Purposes of the processing and the legal basis for the processing
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.
To provide you with information about other services we offer that are similar to those that you have already purchased, been provided with or enquired about.
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.
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 to 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 send market updates directly to you or introduce you to a client (if you are a candidate).
Our Legitimate Business Interests
Our legitimate interest 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, temporary worker 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 database 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. To successfully match the candidates with the clients we need to retain information such as name, contact details, location, job title, area of expertise and additionally for candidates their curriculum vitae, education and training data, identification and right to work documents, salary and rate details.
To deliver our ancillary services we need to detail and map different market sectors with their relevant companies. We make note of organisation’s structures and who is currently employed in certain roles. This then facilitates either an executive search process or provides necessary understanding of who is responsible for the relevant teams and/or who may be the best point of contact to progress things further.
Should we want or need to rely on consent to lawfully process your data we will request your consent verbally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses we will make of your data:
Use of our website;
To notify you about changes to our service;
To ensure that content from our website is presented in the most effective manner for you and for your computer or other device.
We will use this information:
To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
To improve our website to ensure that content is presented in the most effective manner for you and for your computer or other device;
To allow you to participate in interactive features of our service, when you choose to do so;
As part of our efforts to keep our website safe and secure;
To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
To make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them.
We do not undertake 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.
Disclosure of your information inside and outside of the EEA
We will share your personal information with:
Any member of our group both in the EEA and outside of the EEA.
Selected third parties including:
Clients for the purpose of introducing candidates;
Candidates for the purpose of arranging interviews and engagements;
Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
Analytics and search engine providers that assist us in the improvement and optimisation of our site;
Credit reference agencies, our insurance broker, compliance verification partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Flagstaff Consultant Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its clients will be one of the transferred assets.
The lawful basis for the third-party processing will include:
Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
Satisfaction of their contractual obligations to us as our data processor;
For the purpose of a contract in place or in contemplation;
To fulfil their legal obligations.
Where we store and process your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to strive to prevent unauthorised access.
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 haven’t requested your data to be removed. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
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
We will contact you at least once every two years in attempt to update your information on our database
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
The nature of the personal data;
Its perceived accuracy;
Our legal obligations;
Whether an interview or placement has been arranged; and
Our recruitment expertise and knowledge of the industry by country, sector and job role.
We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, pseudonymised data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
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.
A subject access request should be submitted to the Director via email to email@example.com
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on our website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to Flagstaff Consultants Ltd of Tower Point 5th Floor, Platf9rm, 44 North Road, Brighton, England, BN1 1YR.