Updated December 2019
Athwal Resourcing Limited (Company No. 7975088) is a recruitment business which provides work-finding services to its clients and work-seekers. We also provide other related services including outplacement and coaching. Athwal Resourcing Limited, the Company must process personal data (including sensitive personal data) so that we can provide these services â€“ in doing so, the Company acts as a data controller.
Athwal Resourcing Limited hopes that the information detailed within this statement depicts our promise to ensuring that you have a safe and secure experience when on the Website and when having dealings with Athwal Resourcing. However, if you have any concerns or questions in relation to our policy statement, please feel free to contact us by email at firstname.lastname@example.org.
The provision of your personal data to us is voluntary. However, without providing us with your personal data, you will be unable to (as appropriate) apply for roles with us or on behalf of our clients or receive any marketing material we deem appropriate.
How we collect information about you:
(1) When you give it to us DIRECTLY
You may give your personal details (which may include sensitive personal data) to us the Company directly, such as on an job application or registration form or via our website, from LinkedIn, Facebook, Twitter and/or via email, when you apply for employment with us, when you provide us with a business card, or when you apply for roles with our clients.
(2) When you give it to us INDIRECTLY
Your information may be shared with us by, others including users of our services, professional bodies, independent event organisers, sponsors and supporters of our organisation and services. Your information will also be provided to us when you follow us or otherwise interact with us on Twitter, when you like and/or join our page on Facebook or interact with us in other ways on or via Facebook, when you follow us on LinkedIn by either liking or sharing a post.
(3) When you give permission to OTHER ORGANISATIONS to share it or it is AVAILABLE PUBLICLY
We may also collect your personal details (which may include sensitive personal data) from another source such as a jobs board. We may combine information you provide to us with information available from external publicly available sources. Depending on your privacy settings for social media services, we may also access information from those accounts or services. We use this information to gain a better understanding of you and to improve our communications and recruitment related activities.
(4) When you visit our WEBSITE
What data do we collect about you?
We collect personally identifiable information (User Data) that is voluntarily provided by you as jobseekers and other visitors to our Website, job sites and our CRM system. The User Data that Athwal Resourcing Limited receives from the User includes their title, name, address, email address, physical address, telephone and mobile numbers, and any other information provided by you the User via email messages or CV attachments, in the form of photographic evidence, certificates, and not limited to. However, we may request other information where it is appropriate and relevant, for example salary and remuneration package, details of why you have decided to contact us/start a job search, details of topics/areas of interest to you and responses to adverts. This information is then utilised to enable us to provide the User with appropriate work-finding services, as well as for administrative purposes.
The User Data typically collected will assist the User when they wish to:
It is Athwal Resourcing Limited’s policy to limit the information collected and retained to only the minimum information required to complete the User’s request.
Do we process sensitive personal information?
Athwal Resourcing Limitedâ€™s intention is not to seek any sensitive information through our Website unless legally required for recruiting purposes. In limited cases, we may collect sensitive personal data about you which includes a number of types of data relating to race or ethnic origin, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, sexual life, or criminal record only if there is a clear reason for doing so; and will only do so with your explicit consent.
What do we use the User Data for?
Athwal Resourcing Limited process the User Data obtained by the Website, job sites and our CRM system for internal business purposes relating to all aspects of the recruitment process and the sales process associated with it. This data is not shared with others for unrelated purposes and as the sole owner of the information collected, Athwal Resourcing Limited can confirm that we DO NOT sell or share the information given to Third Parties, unless stated below.
Communications, fundraising and marketing
Where you have provided us with your telephone number and e-mail address and you have provided appropriate consent, we may share targeted communications to let you know about events and/or activities that we consider may be of particular interest; job opportunities, about the work and services of Athwal Resourcing, training courses, and to ask for donations or other support as well as advise the User of important and relevant news and industry updates.
We do not knowingly process data of any person under the age of 16. If we come to discover, or have reason to believe, that you are under 16 and we are holding your personal information, we will delete that information immediately.
Purpose of processing and legal basis
The Company must have a legal basis for processing your personal data (which may include sensitive personal data). For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with the terms of the following statement.
We are required to have one or more lawful grounds to process your personal information. The legal bases we rely upon to offer these services to you are:
Applicable law allows User Data to be collected and used if it is reasonably necessary for our legitimate activities (as long as its use is fair, balanced and does not unduly impact individuals’ rights).
Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
Athwal Resourcing Limited will be relying on legitimate interest for processing the User Data when the User accesses the company Website and/or applies for a vacancy via the company Website, social media or job sites. The “legitimate interests” condition will permit Athwal Resourcing Limited to process any User Data for the vacancy that the User has applied for. If the User has not been successful, the Company will be relying on legitimate interest for up to 6 months for other opportunities or vacancies appropriate for the next career move.
The “consent” condition will require Athwal Resourcing Limited to obtain an agreement from the User to process and hold their personal data for anything outside of the User’s vacancy interest. This will be requested from the User by Athwal Resourcing Limited every 36 months. Please do not send us any personal data if you do not want that information to be used for our customer contacts, work finding or role filling purposes.
Athwal Resourcing Limited with always gain consent from the User to process any User Data if:
We will also ask for your expressed consentfor any direct marketing (other than for work finding services). This will be via electronic communications, such as newsletters, marketing and fundraising emails, for targeted advertising and profiling, and if you ever share sensitive personal information with us.
When we use your personal information, we will consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair in other ways.
Sometimes Athwal Resourcing Limited will be obliged to process User Data due to legal obligations which are binding to us. We will only ever do so when strictly necessary.
Most of our interactions with individuals and website users are voluntary and not contractual. However, sometimes your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract for employment opportunities with Athwal Resourcing Limited. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data is Athwal Resourcing will not be able to employ you, or work on your behalf or hold any personal data related to you.
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.
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.
Athwal Resourcing Limited will not hold any User Data the CRM system Profile for any longer than three years, without renewing permission from the User.
Where the Company has obtained your consent to process your personal/and sensitive personal data, we will do so in 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 personal data/and sensitive personal data.
Please be aware that you have the following data protection rights:
1 Right To Withdraw Consent – Where we rely on your consent to use your personal data/and sensitive personal data, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for direct marketing purposes or to be unsubscribed from our email list at any time.
3 Right To Make A Subject Access Request (SAR) – Each User has the right to access the personal data they have submitted to Athwal Resourcing Limited at any time and request a copy of that information. Athwal Resourcing Limited is committed to respond to you within one month, this can be extended to a further two months in certain circumstances. Athwal Resourcing Limited will also ensure that the information is correct and up to date.
Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity, we will have 30 days to comply.
4 Right Of Erasure (also known as the right to be forgotten) – You can ask for your personal information to be deleted from our records. We can keep your personal data if we have a legal reason for doing so. In many cases, we will ask you if you just do not want to hear from us for a period of time or whether you want your data to be permanently deleted. We would propose to suppress further communications with you, rather than delete it.
The User can do this by sending an email to email@example.com, stating whether they would like their User Data to be hidden for a certain period of time or whether they would prefer for their User Data to be removed permanently. We also have an option at the foot of all emails from Athwal Resourcing Limited to ‘unsubscribe’ from Athwal Resourcing Limited.
5 Right Of Rectification – If you believe our records of your personal information are inaccurate or incomplete, you have the right to ask for those records to be updated. Athwal Resourcing Limited will respond to your request within one month.
If the User Data we hold is incorrect or needs updating then the User should contact Athwal Resourcing Limited Data Controller at firstname.lastname@example.org.
6 Right To Restrict Processing – You have the right to ask for processing of your personal data to be restricted if there is disagreement about its accuracy or legitimate usage.
7 Right To Data Portability – To the extent required by the General Data Protection Regulations (GDPR) where we are processing your personal information (i) under your consent, (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contact or (iii) by automated means, you may ask us to provide it to you – or another service provider – in a machine-readable format.
8 Right To Object – You have the right to object to your data being processed.
9 Right In Relation To Automated Decision Making – You have the right not be subject to a decision based on automated processing, unless you have given your explicit consent. Athwal Resourcing Limited endeavour to always have human intervention into any decision making.
To exercise any other of the above rights, please send a description of the personal information in question to email@example.com
Please note that some of these rights only apply in limited circumstances. The Information Commissioner’s Office (ICO) have highlighted that this is not an absolute right and we may keep your personal data on our systems if we have a legal reason for doing so. For more information, we suggest that you consult ICO guidance – https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
How do I make a complaint to the Information Commissioner’s Office (ICO)?
Athwal Resourcing Limited adheres to responsibly handling all User Data in line with company good practice. Should the User have any concerns regarding this or believes that Athwal Resourcing Limited is not being compliant with protecting their User Data, then they have the right to make a formal complaint. If you wish to complain about this privacy notice or any of the procedures set out in it please send an email to firstname.lastname@example.org at Athwal Resourcing Limited.
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/make-a-complaint/your-personal-information-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.
When can we send your information to Third Parties?
It is Athwal Resourcing Limited’s policy to only disclose User Data to Third Parties in the following circumstances:
This Website does not collect or compile personally identifying information for dissemination or sale to outside parties for consumer marketing purposes, or host mailings on behalf of third parties.
Using our Third Party links
‘Cookies’ are small amounts of personal information that a website can send to the User’s computer browser so that it can be recognised on connection with our Website upon the Users return. In turn, this allows the server to make downloading pages faster than on first viewing. Athwal Resourcing Limited also uses these cookies to save information for job or course searches and establish statistics about the use of our Website by Users. This information will allow Athwal Resourcing Limited to improve the quality of the Website.
If you do not wish to have any data collected, we recommend that you do not use our Website. Alternatively, the User can set their browser to block the recording of cookies on their hard drive to minimise the amount of data that may be collected when navigating on our Website. Cookies used on the Website are only active for the duration of the visit and will not be stored on the User’s computer once the web browser is closed.
How secure is your data?
Athwal Resourcing Limited will endeavour to ensure that there are appropriate and proportionate technical and organisational measures to prevent the loss, destruction, misuse, alteration, unauthorised disclosure or access to your personal information.
All of our employees follow a strict security policy and only authorised personnel have been given access to personally-identifiable information. To ensure that confidentiality is upheld all employees are required to agree and sign a confidentiality agreement.
Your information is only accessible by appropriately trained staff, volunteers and contractors. Athwal Resourcing Limited may also use third party suppliers to process data on your behalf.
The Company may transfer only the information you provide to us to countries outside the European Economic Area (EEA) for the purposes of providing you with work-finding 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.
Athwal Resourcing Limited reserves the right to modify or amend this policy at any time. The effective date is always displayed at the beginning of this document and should any part of the policy change, either due to business reasons or future changes in legislation, Users will be notified via our website.
Our copyright rules
All the documents, programmes, designs, processes, information, and ideas (Content) provided on our Website remains the property of Athwal Resourcing Limited, where they are not already owned by others. The Content is provided to Users of the Website for informational purposes only and Users may print or save one copy of any page of the Site and documents available through it (other than documents provided by third parties) for their own personal use.
We are not required by law to have a ‘Data Protection Officer’ however we have a Data Protection Manager.
Please let us know if you have any queries or concerns whatsoever about the way in which your data is being processed by either emailing the Data Protection Manager at email@example.com or by writing to us at the following address:
The Data Protection Manager
Athwal Resourcing Limited
Black Country House
Rounds Green Rd
Oldbury B69 2DG
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