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Privacy & GDPR

Privacy & GDPR for recruitment agencies

  • Privacy & GDPR Howard Finley Ltd is committed to protecting and respecting your privacy. This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our approach to your personal data and how we will treat it. About the GDPR The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) replaced the Data Protection Directive (95/46/EC) and aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a clear framework within which organisations must operate. The GDPR continues to apply in UK law following Brexit, alongside the UK Data Protection Act. Your rights Under the GDPR you have a number of rights in relation to your personal data. These rights are set out in full within this notice. For the purposes of applicable data protection legislation, the data controller is: Howard Finley Ltd 26 Horseshoe Park Horseshoe Road Pangbourne Reading RG8 7JW United Kingdom

How we collect and use your personal data

  • Howard Finley Ltd is a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003. In addition to our core recruitment services, we also provide outsourcing, contracting and marketing services. To carry out our business activities, we collect personal data from the following groups of individuals: Prospective and placed candidates for permanent or temporary roles Prospective and live client contacts Supplier contacts who support our services Employees, consultants and temporary workers The personal data we collect is used solely to carry out our core business and associated activities, in accordance with applicable data protection legislation.

Information you give to us or we collect about you

  • This is information you provide directly to us, whether by filling in forms on our website, corresponding with us by phone or email, or interacting with us in any other way. This includes information provided when registering on our site, entering our candidate database, attending events, participating in surveys or reporting a problem with our site. The personal data we collect may include your name and address, demographic information such as postcode, personal and corporate email address and phone number, financial information, compliance documentation and references verifying your qualifications, experience and right to work in the United Kingdom, curriculum vitae and photograph, employment details and preferences, as well as links to professional profiles available in the public domain such as LinkedIn or other professional networks.

Information we collect about you when you visit our website

  • Each time you visit our website, we automatically collect the following technical information: Your IP address, login information where applicable, browser type and version, the full URL of pages visited, products and jobs you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information such as scrolling, clicks and mouse-overs, methods used to navigate away from the page, and any phone number used to contact our customer service team.

Information we obtain from other sources

  • This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, business cards, personal recommendations and relevant professional networks. Where we collect data in this way, we will inform you within a maximum of 30 days of collecting it, confirming that we hold personal data about you, the source from which it originated, whether it came from publicly accessible sources and the purpose for which we intend to retain and process it. We work closely with a number of third parties including companies within our group, business partners, sub-contractors providing technical, professional and payment services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors. We may receive information about you from these parties for the purposes of our recruitment services and associated support activities.

Purposes of the processing and the legal basis for the processing

  • We use the information we hold 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, products and services that you request from us or that we believe will be of interest to you based on your career or the needs of your organisation. To provide you with information about other services we offer that are similar to those you have already used, been provided with or enquired about. The core service we offer to candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service extends beyond placement to supporting individuals throughout their careers and helping businesses with their broader resourcing needs and strategies. Our legal basis for processing personal data is our legitimate business interests, as described below, although we also rely on contract, legal obligation and consent for specific uses of data: We rely on contract where we are negotiating or have entered into a placement agreement with you or your organisation, or any other contract to provide or receive services. We rely on legal obligation where we are required by law to hold information about you in order to fulfil our legal obligations. We rely on consent for particular uses of your data where legally required, such as when seeking permission to introduce you as a candidate to a client. Where consent is required, we will ask for your express agreement.

Legitimate business interests

  • Our legitimate interests in collecting and retaining your personal data are as follows: Howard Finley is a recruitment business and recruitment agency. We introduce candidates to clients for permanent employment, temporary worker placements and independent professional contracts. The exchange of personal data between candidates and client contacts is a fundamental and necessary part of this process. In order to support our candidates' career aspirations and our clients' resourcing needs, we maintain a database of candidate and client personal data containing both historical information and current resourcing requirements. To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts. To deliver our services effectively we also need to contact candidates on a regular basis through various channels, including email, phone, job alerts and other relevant notifications.

Consent

  • Where we need to rely on consent to lawfully process your data, we will request your consent orally, by email or through an online process for the specific activity requiring consent, and will record your response on our system. Where consent is the lawful basis for our processing, you have the right to withdraw that consent at any time. We may also use your data for the following purposes: To manage and improve your experience of using our website To notify you about changes to our services To ensure that content from our site is presented in the most effective manner for you and your device

We will use this information

  • We will use this information for the following purposes: To administer our site and for internal operations including troubleshooting, data analysis, testing, research and statistical purposes. To improve our site and ensure that content is presented in the most effective manner for you and your device. To allow you to participate in interactive features of our service where you choose to do so. To keep our site safe and secure. To measure the effectiveness of advertising we serve and to deliver relevant advertising to you. To make suggestions and recommendations to you and other users about goods or services that may be of interest. We do use computer systems to search and identify personal data in accordance with parameters set by a member of our team. However, a person will always be involved in the decision making process.

Cookies

  • Our website uses cookies to distinguish you from other users, helping us to provide you with a good browsing experience and to improve our site over time. We use cookies to identify and track visitors, their usage of the website, their access preferences and for advertising purposes. If you wish to control your cookie settings, we encourage you to manage these through your browser settings. We may share your personal information with any member of our group, both within the EEA and outside of it.

Selected third parties including:

  • We may share your personal information with clients for the purpose of introducing candidates to them, and with candidates for the purpose of arranging interviews and engagements. We also share information with clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you, including sub-contractors such as email marketing specialists, event organisers and payment and other financial service providers. We may share data with advertisers and advertising networks that require it to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregated information about our users to help them reach their target audience. We also share information with analytics and search engine providers that assist us in the improvement and optimisation of our site, as well as with credit reference agencies, our insurance broker, compliance 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.

Where we store and process your personal data

  • The data 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, and may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, including those engaged in the provision of recruitment and support services. By submitting your personal data, you agree to this transfer, storage 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 and any payment transactions will be encrypted. Where you have been given or have chosen a password to access certain parts of our site, you are responsible for keeping that password confidential and we ask that you do not share it with anyone. Please be aware that 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 data transmitted to our site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

We will disclose your personal information to third parties:

  • We may also disclose your personal data in the following circumstances: In the event that we sell or buy any business or assets, we will disclose your personal data to the prospective seller or buyer of such business or assets. If Howard Finley or substantially all of its assets are acquired by a third party, personal data held about our customers will be among the transferred assets. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of supply of services and other agreements, or to protect the rights, property or safety of Howard Finley, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. If you require any further information about how we handle your personal data, please do not hesitate to get in touch with our team. Reply

The lawful basis for the third party processing will include:

  • Their own legitimate business interests in processing your personal data, in most cases to fulfill 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.

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 are happy for us to do so. 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:

Our website enables you to manage your data and review whether the details we hold about you are accurate. Prior to making an introduction we check that the information we hold about you is current and correct, and we keep in touch with you so that you can inform us of any changes to your personal data.

We segregate our data so that different types of information are retained for different time periods, in accordance with our data retention policy. We may archive part or all of your personal data, or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Management (CRM) system where appropriate.

Where you have requested suppression or deletion of your data, we may pseudonymise parts of it to ensure that your personal data is not re-entered onto our database unless specifically requested. Pseudonymised data is created by taking identifying fields within a database and replacing them with artificial identifiers or pseudonyms.

Our full retention notice is available upon request.

 
 
 

Your rights

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 – Howard Finley Ltd, 26 Horseshoe Park, Horseshoe Road, Pangbourne, Reading, RG87JW, UK.

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

Request erasure

Object to processing

Request the restriction of processing

Request the transfer

Make a complaint

The nature of the personal data.

Its perceived accuracy.

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). Prior to 25th May 2018 any access request under the Data Protection Act will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

A subject access request should be submitted to info@howard-finley.co.uk No fee will apply once the GDPR comes into force.

Changes to our privacy notice as trades & labour agencies in London

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to see any updates or changes.

Contact

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to DPO, Howard Finley Ltd, 26 Horseshoe Park, Horseshoe Road, Pangbourne, Reading, RG87JW, UK.