Protecting your privacy
|Company Name:||Eton Bridge Partners Limited (‘the Company’)|
|Company Contact details:||Gill Birrell, Finance Director and Company Secretary
Riverside House, Riverside Walk, Windsor SL4 1NA
|Date:||Revised April 2022|
This Privacy Notice explains in detail what personal data we will process and how we will keep it safe. We want you to be fully informed about your rights and how we will use your data. We may need to update this Privacy Notice from time to time and if there are any significant changes we will let you know. You are welcome to request a current copy by writing to us at the address above (Company Contact details) or to email@example.com at any time or you can visit our website to view the latest version.
Eton Bridge Partners is a recruitment business, offering interim management, executive search and consultancy services to its clients and candidates. The Company must process personal data (including sensitive personal data) so that it can provide these services. In doing so, the Company acts as a data controller.
For the purposes of providing you with recruitment services and/or information relating to your future career, we will only use your personal data in accordance with the terms of this privacy statement. At all times we will comply with current data protection laws.
Collection and use of personal data
Categories of personal data we collect
If you are a candidate, we may collect the following categories of personal data:
- Your full name, gender, age, date of birth and marital status;
- Evidence of your right to work in the UK which may include a photograph, nationality, place of birth, birth certification, driving licence
- Contact details including your email, home address, phone numbers so that we can contact you;
- Bank account and national insurance number (so we can reimburse interview expenses to you and fulfil our HMRC reporting duties);
- Your job search criteria, preferences and expectations;
- Your qualifications, skills, experience and training;
- Your current working patterns and flexible working arrangements;
- Current and desired remuneration/payrate and other benefits;
- Educational history;
- Employment history;
- Details of employment or educational referees;
- Details of disabilities or neurodiversity; Details of any criminal convictions;Other information contained on your CV or that you choose to provide us;
- Marketing and communications data including your marketing and communication preferences;
If you are a client or supplier or potential client or supplier of the Company, we will collect and process personal data about individuals in your organisation. This may include name, business email address, job title, telephone number and business postal address.
We may collect personal data revealing your racial or ethnic origin, political opinions, religious or philosophical belief, trade union membership, caring responsibilities, genetic data, biometric data, data concerning health, sex life or sexual orientation (“Sensitive Personal Data”), if relevant and we shall do so in accordance with this Privacy Notice and applicable data protection laws.
How we collect your personal data
You may give your personal details to the Company directly, such as on your Curriculum Vitae, in an email to us, during interviews or telephone calls or we may collect them from another source such as a job board or LinkedIn. Your referees may disclose personal information about you with us. Our clients, suppliers and other candidates may share personal information about you with us.
Purpose of processing
The Company will collect your personal data (which may include Sensitive Personal Data). We will process your personal data for the purposes of providing you with recruitment services. This includes for example, contacting you about potential roles, assessing your suitability for those roles, updating our databases, putting you forward for job opportunities, arranging payments to you, assessing your performance, and developing and managing our services and relationship with you and our clients.
We may also provide career guidance which may or may not be part of a recruitment process.
We may also send you marketing information and news via email/ text. In order to do so, we need your consent which we will ask for via an opt-in. You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us or by contacting us at firstname.lastname@example.org.
In some cases we may be required to use your data (including Sensitive Personal Data) for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us (including employment-related laws). We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.
The legal bases we rely upon to process your personal data are:
• Legitimate interest
• Statutory obligation
• Contractual obligation
This is where the Company has a legitimate reason to process your data which is necessary for the purposes of the legitimate interests pursued by us except where such interests are overridden by your interests or fundamental rights or freedom which require protection of personal data. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
• Managing our database and keeping candidate records up to date;
• Providing recruitment services to you and our clients and to facilitate the recruitment process;
• To ensure internal administrative activities run smoothly, such as facilitating payment and invoicing processes (where relevant);
• Complying with out legal obligations in connection with the detection of crime or the collection of taxes or duties;
• Enabling us to send you targeted job recommendations, relevant marketing materials or other communications which we think are likely to be of interest to you; and
• Contacting you to seek your consent where we need it.
The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.) In addition, we may need your personal data to enter into a contract with you. If you do not give us personal data we need to collect as a result of statutory/contractual obligations, we may not be able to continue to provide our services to you.
In certain circumstances, we are required to obtain your consent to the processing of personal data in relation to certain activities. You have the right to withdraw your consent to these activities at any time. Please see “Your Rights” below for more information.
Where the Company has obtained your consent to process Sensitive Personal Data, we will do so in line with our ‘Policy for managing special categories of data’, a copy of which is available on request.
Disclosure of your personal data
The Company will disclose your personal data and/or Sensitive Personal Data with the following recipients:
- Our clients (whom we may introduce or supply you to);
- Former employers whom we may seek references from;
- Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to;
- Other recruitment agencies in the supply chain;
- Our system providers includingthe providers of our CRM database; and Etz Payments Ltd (provider of our timesheet and invoicing system);
- Arpeo Solutions or Colvill Banks, both divisions of White Crow Research Ltd (CV reformatting service provider);
- Affiliates within our group of companies; and
- Third parties to whom we may choose to transfer the assets of our business.
The Company may transfer only the information you provide to us to countries outside the UK or the European Economic Area (‘EEA’) for the purposes of providing you with recruitment services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
Where we hold work-seeker records, we must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently 3 to 6 years.
Where we have obtained your personal data as part of a recruitment process, we will retain it for a maximum period of 5 years. In certain circumstances where we have engaged with you during that 5- year period, we may retain your personal data for a longer period but we shall only retain is for as long as is necessary for the purposes set out in this Privacy Notice.
The Company takes every precaution to protect our users’ information. Our systems are protected by a number of security solutions including a firewall, Microsoft Intune, anti-malware, multi-factor authentication, mobile application management and disk encryption. There is a strict password policy and user access is controlled using the Active Directory.
Only employees who need the information to perform a specific job (for example, consultants, our accounts team or our marketing team) are granted access to your information.
The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason, the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet.
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you;
- The right of access to the personal data the Company processes 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 where the processing is for: (a) a task carried out in the public interest; (b) the exercise of official authority vested in you; (c) your legitimate interests (or those of a third party); or (d) direct marketing purposes;
- 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 the Company processing special categories of your personal data you have the right to withdraw that consent at any time by contacting the Finance Director, Eton Bridge Partners Ltd, Riverside House, Riverside Walk, Windsor, Berkshire SL4 1NA. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want to exercise any of the other rights listed above.
Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Finance Director, Eton Bridge Partners Ltd, Riverside House, Riverside Walk, Windsor, Berkshire SL4 1NA.
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.