Privacy Policy Extended

privacy policy extended
protecting your personal data
View our extended Privacy Policy information below:
extended privacy policy information

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?
This document provides you with much more insight into what data we collect about you. Here’s a more detailed look at the information we may collect. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.

Client Data: The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, our calls with you may be recorded, depending on the applicable local laws and requirements. If we need any additional personal data for any reason, we will let you know.

Candidate Data: Depending on the relevant circumstances and applicable laws and requirements, we may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions:

Name;
Age/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/birth certificate;
Financial information (where we need to carry out financial background checks);
Social security number (or equivalent in your country) 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 choose 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;
The dates, times and frequency with which you access our services; and
CCTV footage if you attend our premises. The CCTV is managed by Central Working, and they can be contacted at http://www.centralworking.com/contact

Please note that the above list of categories of personal data we may collect is not exhaustive.

HRMS Employee Data:  The data we collect is to enable us to meet the requirements of a contract with the organisation. We will process data only on the instruction from the client organisation. The data in which the organisation collects and how it is used is outlined in the Client organisation employee privacy statement.

Supplier Data: We do not collect much data about Suppliers – we simply need to make sure that our relationship runs smoothly. We will collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We’ll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance team, our calls with you may be recorded, depending on the applicable local laws and requirements.

People whose Data we receive from Candidates or HRMS Client Employees, such as Referees and Emergency Contacts: All we need from referees is confirmation of what you already know about our Candidate, so that they can secure that job they really want. Emergency contact details give us somebody to call on in an emergency. To ask for a reference, we will need the referee’s contact details (such as name, email address and telephone number). We will also need these details if our Candidate 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 from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This 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 YOUR PERSONAL DATA?
Candidate Data: We collect Candidate personal data in three primary ways:

1. Personal data that you, the Candidate, give to us;

2. Personal data that we receive from other sources; and

3. Personal data that we collect automatically.

Personal Data you give to us:

call hr needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities and service, and should save you time in not having to trawl through information about jobs and services that are not relevant to you.

There are numerous ways you can share your information with us. It all depends on what suits you. These may include:

Entering your details on the call hr website or via an application form, as part of the registration process;
Completing a Client engagement form
From your organisation or former organisation to enable us to provide a HRMS or TSO service;
Leaving a hard copy CV at a call hr recruitment event, job fair or office;
Emailing your CV to a call hr consultant or being interviewed by them; and/or
Applying for jobs through a job aggregator, which then redirects you to the call hr website or email system.

Personal Data we receive from other sources

We also receive personal data about Candidates and HRMS Employees from other sources. Depending on the relevant circumstances and applicable local laws and requirements, 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, in particular where the Client receives a HRMS;
We may obtain information about you from searching for potential Candidate from third party sources, such as LinkedIn and other job sites;
If you ‘like’ our page on Facebook or ‘follow’ us on Twitter we will receive your personal information from those sites;
If you were referred to us through an TSO or HRMS supplier, they may share personal information about you with us.

Client Data: We collect Client personal data in three ways:

1. Personal data that we receive directly from you;

2. Personal data that we receive from other sources; and

3. Personal data that we collect automatically.

Personal data that we receive directly from you

We want to ensure that you have the best staff for your organisation or you have the best HR support for your employees . We will receive data directly from you in two ways:

Where you contact us proactively, usually by phone or email; and/or
Where we contact you, either by phone or email, or through our consultants business development activities more generally.

Personal Data we receive from other sources

Where appropriate we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:

From third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us);
From delegate lists at relevant events; and
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).

Website Users: When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. 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 may not do this now, but we may in the future. We collect your data automatically via cookies, in line with cookie settings in your browser.
HOW DO WE USE YOUR PERSONAL DATA?
Having obtained data about you, we then use it in a number of ways.

Candidate Data and Client Employee Data: We generally use Candidate and Client Employee data in four ways:

Recruitment Activities
HR Activities
Marketing Activities
Equal Opportunities Activities
To help us to establish, exercise or defend legal claims.
In appropriate circumstances in the future, we may also use Candidate and HRMS Client Employee

Here are some more details about each:

Recruitment Activities

What is important to us is connecting the right Candidates with the right jobs. We’ve listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.

Collecting your data from you and other sources, such as LinkedIn;
Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment;
Providing you with our recruitment services and to facilitate the recruitment process;
Assessing data about you against vacancies which we think may be suitable for you;
Sending your information to Clients, in order to apply for jobs or to assess your eligibility for jobs;
Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think may be of interest to you;
Allowing you to participate in the interactive features of our services, when you choose to do so;
Carrying out our obligations arising from any contracts entered into between us;
Carrying out our obligations arising from any contracts entered into between call hr and third parties in relation to your recruitment;
Facilitating our payroll and invoicing processes;
Carrying out customer satisfaction surveys;
Verifying details you have provided, using third party resources (such as psychometric evaluations or skills tests), or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);
Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; 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 for our legitimate interests. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this here.

Marketing Activities

We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. To:

enable us to develop and market other products and services;
market our full range of recruitment services (permanent, temporary, contract, outplacement, HRMS and TSO) 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 the call hr website as a success story. We will only do this where we have obtained your express consent to do so; and
provide you with information about certain discounts and offers that you are eligible for by virtue of your relationship with call hr.

We 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 (which we explain further below).

Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent.

If you want to know more about how we obtain consent, please click here. If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do so here. We do have many places that your data could be captured. We do want to make sure that you understand that although you have opted out from our marketing communications through the preference opt out, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this does not happen, but if it does, we apologise and we ask that you notify us here or please opt out again.

All our marketing is based on what we think will serve our Clients and Candidates best, but we know we do not always get it right for everyone. We may use your data to show you call hr adverts and other content on other websites, for example Facebook and LinkedIn. If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option. Even where you have turned off advertising cookies, it is still possible that you may see a call hr advert, but in this case it will not have been targeted at you personally, but rather at an anonymous audience.

HR Activities

What is important to us is maintaining Client Employee data as accurate as possible with the data that is provided to us by our Client for processing and using that data to provide the HRMS that we are contracted to by our Client. We’ve listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.

Collecting your data from you, the Client and other sources, such as references, medical reports;
Storing your details (and updating them when instructed to do so by the Client) on a database and our database so that we can contact you in relation to your employment with the HRMS Client;
Providing you with our HR service to support you during your employment with the Client and post employment as required, for example to provide references on behalf of our HRMS Client;
Sending your information to providers of services that our Clients are engaged with in order to meet their contractual obligation. For example, accountants in order to pay you;
Meeting our obligations to provide information to statutory bodies, for example HMRC
Enabling you to submit information for your employee file;
Allowing you to participate in the interactive features of our services, when you choose to do so. For example, the call hr acadamy;
Carrying out our obligations arising from any contracts entered into between our Client;
Carrying out our obligations arising from any contracts entered into between call hr and third parties in relation to your employment;
Facilitating our payroll and invoicing processes or that of your employer;
Carrying out customer satisfaction surveys;
Verifying details you have provided, using third party resources (such as DBS checks, identity checks), or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);
Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; 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.

Equal opportunities monitoring and other sensitive personal data

We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we may (in appropriate circumstances and in accordance with local law and requirements) collect about you comes under the umbrella of “diversity information”. This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. Where appropriate and in accordance with local laws and requirements, we will use this information on an anonymised basis to monitor our compliance with our equal opportunities policy.

We may also disclose this (suitably anonymised where relevant) data to Clients where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes.

This information is what is called ‘sensitive’ personal information and slightly stricter data protection rules apply to it. We therefore need to obtain your explicit consent before we can use it. We will ask for your consent by offering you an opt-in. This means that you have to explicitly and clearly tell us that you agree to us collecting and using this information.

We may collect other sensitive personal data about you, such as health-related information, religious affiliation, or details of any criminal convictions if this is appropriate in accordance with local laws and is required for a role that you are interested in applying for. We will never do this without your explicit consent.

If you would like to find out more about consent, please click here. 

If you are not happy about this, you have the right to withdraw your consent at any time and you can find out how to do so here.

To help us to establish, exercise or defend legal claims

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

Profiling

At present all our recruitment activities involve human-decision making during the process. Should this change in the future we will update this privacy statement.

Where appropriate, we will seek your consent to carry out some or all of these activities. If you do not provide consent to profiling, your application will continue to be reviewed manually for opportunities you apply for, but your profile will not be automatically considered for alternative roles. This is likely to decrease the likelihood of us successfully finding you a new job.

You have the right to withdraw that consent at any time and can find out more about how to do so here.

Client Data: We use Client information for:

Recruitment Activities
Marketing Activities
HR Managed Services
To help us to establish, exercise or defend legal claims

Here are some more details about each:

Recruitment Activities

Our main areas of work are HR and recruitment, through: (i) HRMS (ii) TSO and (iii) providing you with Candidates. We’ve listed below the various ways in which we use your data in order to facilitate this.

Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment activities;
Keeping records of our conversations and meetings, so that we can provide targeted services to you;
Undertaking customer satisfaction surveys; and
Processing your data for the purpose of targeting appropriate marketing campaigns.

Marketing Activities

If you engage with us to support you with HR services or in the recruitment of a new employee, we will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address. We will take your instruction as a soft-opt in. You can find out more about soft-opt in here.

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 here.

To help us to establish, exercise or defend legal claims

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.

Supplier Data: We do want to strike the right balance as such, 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 engage with us to supply a service we will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address. We will take your instruction as a soft-opt in. You can find out more about soft-opt in here.

If you are not happy about this, in certain circumstances you have the right to object and can find out more about how to do so here.

People whose data we receive from Candidates and Client Employees, such as referees and emergency contacts

We will only use the information that our Candidate gives us about you for the following purposes:

If our Candidates put you down on our form as an emergency contact, we will contact you in the case of an accident or emergency affecting them; or
If you were put down by our Candidate as a referee, we will contact you in order to take up a reference. This is an important part of our Candidate quality assurance process, and could be the difference between the individual getting a job or not.
If you were put down by our Candidate as a referee, we may sometimes use your details to contact you in relation to recruitment activities that we think may be of interest to you, in which case we will use your data for the same purposes for which we use the data of Clients.

If you are not happy about this, you have the right to object and can find out more about how to do so here.

Website Users: We use your data to help us to improve your experience of using our website, for example by analysing your recent job search criteria to help us to present vacancies or Candidates to you that we think you’ll be interested in.

If you would like to find out more about cookies, including how we use them and what choices are available to you, please click here. 
 WHO DO WE SHARE YOUR PERSONAL DATA WITH?
Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:

Our partner company, Whitehill Pelham Ltd which incorporates talentdesk;
Individuals and organisations who hold information related to your reference or application, such as current, past or prospective 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 and our Candidates’ 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;
If call hr merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

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. Details of how to contact us can be found here.
HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
We will Delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for two years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.

For those Candidates whose services are provided via a third party company or other entity, “meaningful contact” with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than two years from that point or, if later, for the period of two years from the point we subsequently have meaningful contact directly with you.

When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a Candidate we will consider there to be meaningful contact with you if you submit your updated CV onto our website or take part in any of our online training. We will also consider it meaningful contact if you communicate with us about potential vacancies, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.

For Clients engaged with us on a HRMS, we will retain personal data in-line with the Client data retention policy or should the engagement come to an end, we will Delete the data 30 days after the engagement has ended, unless we are required to keep the data to meet statutory requirements.
HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?
One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain 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 us. We will seek to deal with your request without undue delay, and in any event 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, HRMS Client Employees, 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, for our marketing arrangement), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that 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. 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”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. 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 (Delete): You have the right to request that we erase 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 to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found here.

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), details of how to contact us can be found here. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

You may ask to unsubscribe from job alerts at any time.

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.

If we provide a HRMS, you should keep us informed of accurate personal information via the approach agreed with your organisation.
WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA ON THE CALL HR WEBSITE?
call hr is responsible for processing your personal data if we collect it on the call hr website.

If you have any comments or suggestions concerning this Privacy Policy please contact us. We take privacy seriously so we’ll get back to you as soon as possible.
HOW DO WE TRANSFER YOUR DATA INTERNATIONALLY?
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 call hr business);

– to other third parties, as referred to here.

We want to make sure that your data is 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
by ensuring the companies have signed up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; 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
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.

If you are an HRMS Client employee, we will only transfer your Data Internationally on instruction from the organisation and where appropriate your consent will be sought.
COOKIES POLICY
What is a cookie?

A “cookie” is a piece of information that is stored on your computer’s hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.

Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.

How do we use cookies?

We use cookies to track the traffic to our website. This enables us to understand how our website is used and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need

Cookies are either:

Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalisation (see below).

Cookies can also be categorised as follows:

– Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.

The cookies we use are Google Analytics and Facebook Connect
OUR LEGAL BASES FOR PROCESSING YOUR DATA
We have outlined below our legal bases for processing your data. The legal bases are stated for each scenario. We do not think that any of the following activities prejudice individuals in any way – we think they help us to offer you a more tailored, efficient service.

Client Data

Article 6(1)(f) of the GDPR is the one that is relevant – 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.”

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 these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.

Candidate Data

Article 6(1)(f) of the GDPR is the one that is relevant – 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 consider it is 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 is looking like you may get the job, your prospective employer may also want to double check any information you have given us (such as the results from psychometric evaluations or 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 is 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.

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 click here.

HRMS Employee Data

Three articles are relevant:

Article 6(1)(b) of the GDPR – processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering in to a contract;
Article 6(1)(c) of the GDPR – processing is necessary for compliance with a legal obligation to which the controller is subject; and
Article 6(1)(f) of the GDPR – processing 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 consider that it is essential to process personal data to enable us to meet the contractual obligations for the HRMS. We will process data on the instruction of the organisation.

We want to ensure that we can provide the advice, guidance and tailored information, relevant articles, notifications to the organisation (HRMS Client). We need to do these things so that we can function as a profit-making business, and to help the organisation, the controller of the data, meet the requirements of Article 6(1)(b), Article 6(1)(c), Article 6(1)(f).

To ensure we can provide an effective service to meet our contractual requirements, we will store your personal data and/or the personal data of individual employees at your organisation as well as keeping records of conversations with employees and meetings. We will maintain HRMS Client employee data as instructed by the organisation (HRMS Client). From time to time, we may also ask you to undertake a customer satisfaction survey.

Supplier Data

Article 6(1)(f) of the GDPR is the one that is relevant – 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 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.

People whose Data we receive from Candidates and HRMS Client Employees, such as Referees and Emergency Contacts:

If you have been put down by a Candidate or HRMS Client Employee as one of their referees, we use your personal data in order to contact you for a reference.

We may process Data of this nature for two reasons:

Candidates – 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 talent search services

HRMS Employees – This is required for the HRMS organisation for the performance of a contract

If a Candidate or HRMS Client Employee 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 or for the performance of a contract.
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 found here.
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 entity responsible for processing the personal data of Website Users: call hr Limited

How you can get in touch with us:

You may want to get in touch with us for the following reasons:

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);

You may also feedback concerning this Privacy Policy

You can write to us at the following address:

call hr Ltd, The Bradfield Centre, 184 Cambridge Science Park, Milton Road, Cambridge, CB4 0GA

Alternatively, you can send an email to: [email protected]

How you can get in touch with us to update your marketing preferences

You can do this by opting out using the unsubscribe link in any marketing material we send to you, or send an email to [email protected]
HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY
The UK supervisory authority is: The Information Commissioner’s Office.

You can contact them in the following ways:

Phone: 0303 123 1113

Email: [email protected] or Live chat.

Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
GLOSSARY

Candidates– includes applicants for all roles advertised or promoted by call hr, including permanent, part-time and temporary positions; as well as people who have supplied a speculative CV to call hr not in relation to a specific job. Individual contractors, freelance workers and employees of suppliers or other third parties put forward for roles with call hr, Clients as part of an HRMS
Clients – while it speaks for itself, this category covers our customers, clients, and others to whom call hr provides services in the course of its business. This may be a HRMS or TSO.
HRMS Client Employee – This specifically relates to those employees that currently are employed by the company we provide a HRMS to, and those employees who are no longer an employee of the company we provide a HRMS to.
Staff – includes employees and interns engaged directly in the business of call hr (or who have accepted an offer to be engaged) as well as certain other workers engaged in the business of providing services to call hr (even though they are not classed as employees). For these purposes we also include employees of call hr who are engaged to work on Clients’ premises under the terms of TSO or HRMSClientsCandidates and are covered by this Privacy Policy. Likewise, independent contractors and consultants performing services for call hr fall within the definition of a ‘Supplier’ for the purposes of this Privacy Policy.
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
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.
HR Managed Service (HRMS) – full or partial outsourcing of the HR support or HR projects for the business by
Other people whom call hr may contact – these may include Candidates’ and their emergency contacts and referees. We will only contact them in appropriate circumstances.
Talent Source Outsourcing (TSO) services – full or partial outsourcing of the recruitment process for permanent employees to a recruitment provider.
Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to call hr. In certain circumstances call hr will sub-contract the services it provides to Clients to third party suppliers who perform services on call hr’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, call hr 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 call hr websites.