First People Recruitment (“the Company”)
The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company collects and processes personal data (including sensitive personal data) or personal information, relating to its employees, workers, work-seekers & job applicants, so that it can provide these services – in doing so the Company acts as a data controller.
The Company is committed to safeguarding the privacy and security of your personal data and to meeting its data protection obligations under the General Data Protection Regulations (“GDPR”) and the Data Protection Act 2018.
Under the GDPR, we must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:
- Your consent
- Where we have a legitimate interest
- To comply with a legal obligation that we have
- To fulfil a contractual obligation that we have with you
This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. 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 work-seeker records up to date;
- Providing work-finding services to you and our clients;
- Contacting you to seek your consent where we need it;
- Giving you information about similar products or services that you have used from us recently;
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.) Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us personal data we need to collect we may not be able to continue to provide work-finding services to you.
Who has access and who we share your personal data with?
The Company may share your personal data internally within the Company, including members of the payroll staff and other Company employees if access is necessary for the performance of their roles.
The Company may also process your personal data and/or sensitive personal data with the following recipients:
- Clients (whom we may introduce or supply you to)
- Pension scheme providers
- Former employers whom we may seek references from
- Payroll service providers or umbrella companies who manage payroll on our behalf
- Other recruitment agencies in the supply chain
- External IT and Customer Relationship Management (CRM) service providers
- External auditors who carry out audits to ensure that our business is run in accordance with contractual and legislative requirements
- Any public information sources and third party organisations that we may use to carry out suitability checks e.g. the Disclosure and Barring Service (DBS), Nursing and Midwifery Council (NMC). Credit reference agencies, DVLA
- Government, law enforcement agencies and other regulators e.g. HMRC, Gangmasters Licencing Authority (GLAA), Police, Home Office
- Our Insurers/professional advisers (to maintain insurance cover, obtain professional advice and for managing legal disputes)
We may also share your personal data with third parties where it is necessary to administer the contract we have entered into with you, where we need to comply with a legal obligation, or where it is necessary for our legitimate interests.
Your Personal Data and how we collect it
Personal Data is any information about an individual from which that person can be directly or indirectly identified. It does not include anonymised data i.e. where all identifying particulars have been removed.
The Company collects, uses and processes personal information about you, including the following (as applicable):
- Contact details, including your name, address, telephone number and email address
- Date of Birth
- Marital Status
- A copy of your driving license and/or passport/identity card (for identity and right to work checks)
- Nationality (through right to work check)
- Immigration Status (whether you need a work permit)
- Emergency contact details
- Work and Education History
- Details of your skills, qualifications and experience, both with previous employers and with the Company
- Professional memberships
- Salary, entitlement to benefits and pension information
- Bank account, national insurance number and tax code (so we can make payments to you and account for tax if you are working as a temporary worker for FPR Group)
There are also “special categories” of personal information which requires a higher level of protection because it is of a more sensitive nature.
The Company may also collect, use and process the following special categories of your personal information (as applicable):
- Health information including whether you have a disability
- Criminal convictions and offences
- Individual’s racial or ethnic origin
- Sexual orientation
- Genetic and biometric data
- Trade union memberships
How we collect it
The Company may collect personal data in a variety of ways, during the recruitment process, either directly from you or sometimes from a third party, including the following:
- From personal data that you, the Employee, Candidate, temporary worker give to us
- From job boards for example, Jobsite, CV Library, Reed, LinkedIn
- A former employer
- A referee whose details you provided to us
Your personal data may be stored in different places, including your application file, our Payroll software, recruitment database and other IT systems, such as e-mail.
How long does the Company keep your personal data?
The Company will only retain your personal data only for as long as is necessary for the purpose we collect it. This means we will keep your personal data information throughout the period of your relationship with us and whilst we are providing you with work finding services. If you no longer wish to receive our services we will continue to retain your personal data on our CRM for a further period of 2 years after our relationship ends, so we can comply with our regulatory obligations.
We must also keep your payroll records, holiday pay, sick pay and pension’s 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 the Company has obtained your consent to process your sensitive personal data, we will do so line with our Retention Policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your sensitive data.
Yours Legal Rights
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your working relationship with us, e.g. you change your home address.
You have a Legal Right to the following:
- 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 that was based on a public or legitimate interest;
- The right not to be subject to automated decision making and profiling; and
- The right to withdraw consent at any time.
Currently we do not use automated decision making technologies to make final or conclusive decisions about you and a member of our staff will always be involved in the provision of work finding services.
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.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details below and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the details below if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
We may obtain data about you from cookies. These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.
The Company’s website may contains links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.
The Company will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein
Sale of business
If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
The Company takes every precaution to protect the personal data that we hold from misuse, loss, unauthorised access, altered or disclosed. Only employees who need the information to perform a specific job e.g. consultants, accounts clerks 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.
If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered.
Changes to this Privacy Statement
We may update this policy from time to time by publishing a new version on our website. If we change material terms we will provide notice of the revised Privacy Statement for 30 days on our home page at www.fprgroup.com
Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Adele Walker via email [email protected] or telephone 01273 202453.
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.
First People Recruitment Limited
22 Queens Road