Privacy Notice

Who we are and the purpose of this document
This privacy notice is issued by Source Recruitment Specialists Limited (Source) whose registered office is 39/41 High Street, St Peter Port, Guernsey GY1 2JT. Telephone number 01481 701616. We are committed to respecting and protecting your privacy and the confidentiality of any information that we hold on you. We therefore process your personal data in accordance with the Data Protection (Bailiwick of Guernsey) Law, 2017 (DP Law).

Under the DP Law, Source is a "controller". This means that we are responsible for deciding how we hold and use personal information about you.
This privacy notice applies to;

-any person (candidate) who contacts us enquiring about our employment or work finding services (whether paid or not);

-any person (candidate) who registers with us as a candidate and/or is applying for work with us or one of our clients (whether as an employee, temporary worker, voluntary worker, work experience or seasonal placement) or;

-any person (candidate) who registers to receive vacancy notifications via our website. 

It makes you aware of how and why your personal data will be used, how long it will be retained and your rights generally in relation to your personal data. It also provides you with certain information that must be brought to your attention in accordance with obligations under the DP Law.

Our commitment to you
As with all responsible organisations, it is our intention to at all times comply with the DP Law and principles, which means that your data will be:

  • Used lawfully, fairly and in a transparent way;
  • Used only for the purposes that we have clearly explained to you and limited only to those purposes;
  • We will only ask you for the minimum amount of information necessary;
  • Kept accurate and kept up to date;
  • Kept only as long as necessary for the purposes we have told you about; and
  • Kept securely.

How do we collect your personal data?
We collect personal information about you from the following sources:

  • You, the candidate;
  • With your permission, credit reference agencies;
  • With your permission, The Disclosure and Barring Service (in respect of criminal convictions);
  • With your permission, your named referees, from whom we collect the following categories of data: employment dates, job title, leaving salary, sickness leave record and reason for leaving; and
  • Publicly accessible sources such as internet, social networks, world-check and/or commercial registers.

What data do we collect about you?
In connection with your registration as a candidate with us, we will collect, store, and use the following categories of personal information about you:

  • The information you provide to us in your curriculum vitae, covering letter or email and any telephone conversations with us;
  • The information you provide on our candidate registration form, includes your name, address, telephone number, personal email address, date of birth, due diligence information, details about your current and/or previous employment history, remuneration, benefit entitlements and future employment aspirations;
  • Any relevant information you provide to us during a registration meeting or telephone conversations;
  • Any due diligence information you provide to us in order to engage you as an employee of one of our clients. This includes documentation to confirm your identification, right to live and work in Guernsey, police disclosures, academic and/or professional qualification certificates, any reference information obtained from third parties about you and/or your previous employment and credit checks (where necessary);
  • If we secure you Temporary employment with one of our clients, the following information will also be required to set you up on our payroll system; social security number, income tax number and bank details;

When required, and only if it’s relevant to the recruitment process, we may also collect, store and use the following special category data:

  • Information about your health, including any medical conditions and health and sickness records;
  • Information about any disabilities you may have and reasonable adjustments you may require; and
  • Information about criminal convictions and offences. 

If you decide to register to receive email notifications about new job vacancies via our website, we will collect your name, email address and ask you to select the sectors you are interested in. You are able to manage your preferences yourself and unsubscribe at any time.

How we will use the personal data you provide to us?
The personal data, not considered to be special category data, which we collect about you, will be used as follows;

As our business concerns recruitment and involves the placement of individual candidates with companies/businesses within the Bailiwick of Guernsey. We will therefore hold and process your personal data as part of our legitimate business interests as a recruitment agency. More specifically, we will collect and process your personal data for the following purposes:

  • To assess your skills, experience, qualifications, and suitability for a particular role or more generally for a particular type of work or Company;
  • To communicate with you about the recruitment process;
  • To keep records related to our recruitment process and progress on your behalf. For example, keeping details of applications made, interviews attended, interview feedback, offers of employment received;
  • To carry out background and reference checks, where applicable.
  • To comply with legal or regulatory requirements; and 
  • To where you have registered on our website, to send you vacancy notification emails and periodic newsletters.

When you apply to register as a candidate with Source and/or have provided us with a copy of your CV and covering letter/email, we will process that information in order to determine whether you meet the basic requirements to perform either a particular role, or a role within a category of roles that you have indicated you would be interested in. If we feel we may be able to help you, we will invite you for a registration meeting and ask you to complete an online registration form. The information you provide to us at that meeting and on the registration form will be used to decide whether we can indeed make applications on your behalf. For active candidates, we will share your information with potential employers in the course of providing employment/recruitment services. Before doing so we will always seek your consent and all potential employers we deal with are subject to obligations of confidentiality in respect of this information. 

The personal data, not considered to be special category data, which we collect about you, satisfies the following lawful conditions:

  • You (the data subject) has requested, or given consent to the processing of the personal data, for the purpose for which it is processed;
  • The processing is necessary for the performance of a contract to which you are a party or that is in your interests; and
  • The processing is necessary for the purposes of legitimate interests.

How will we use special category data you provide to us?
The special category data, which we collect about you, will only be in relation to health and criminal data and is necessary as follows;

  • Health Data. We will use information about your health or disability status (if applicable), solely in consideration of whether our clients need to provide appropriate adjustments during the recruitment process, and should they decide to employ or engage you, whether adjustments will need to be made.

- Criminal Data. Depending on the role (or type of roles) for which you are applying, we may be required or obliged to carry out a criminal record check in order to satisfy ourselves that there is nothing in your history which makes you unsuitable for the role. In particular:

  • We are legally required by certain regulatory bodies to carry out criminal record checks for those carrying out roles or work within particular industries;
  • Where the role is such that it requires a standard or enhanced check from the Disclosure and Barring Service; or
  • Where the role requires a high degree of trust and integrity and/or you are required to be a "fit and proper" person.

The special category data, which we collect about you, satisfies the following lawful conditions;

  • You (the data subject) have given explicit consent to the processing of the personal data for the purpose for which it is proposed.

What happens if you don't want to provide us with your personal data?
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application. Or for example, if we require a credit check or references for a particular role and you fail to provide us with relevant details, we will not be able to take your application further.

Who do we share your personal data with?
We may share, disclose or transfer your personal data with third party service providers or our professional advisers who support our core business services.

All of our third-party service providers or professional advisers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers or professional advisers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. 

Only once you have reviewed job descriptions, researched those employers and provided us with your express permission to do so, will we share your personal data with those select clients for the purposes of securing employment for you.

Except as described in this notice, Source will not transfer or sell your personal data to any third party unless you have specifically consented to this. 

In the event of a sale or potential sale of Source, or where it is merged 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. 

In the unlikely event that a transfer of data is necessary outside of Guernsey and/or the European Economic Area to a country that does not have an adequate level of protection for your personal data, Source will ensure that additional explicit consent is obtained from you or safeguards are put in place to ensure the protection of your personal data.

Where do we keep your data?
Your data may be kept on our Google Workspace cloud-based systems, on our inhouse recruitment software* and if you carry out temporary employment though us, on our payroll system*. *Data is held on our dedicated server held on the cloud hosted by Amazon Web Services (AWS).

How do we keep your personal data secure?
We have appropriate security measures in place on all hardware and software to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Source operates a paperless office and we do not store data locally. Any confidential documents we receive in the mail are scanned and shredded securely and old hard drives are destroyed by certified disk shredders.

Please see our cookie policy for information on how we collect and use your website usage data.

In addition, we limit access to your personal information to those employees who have a legitimate business need to know and all employees are also subject to a duty of confidentiality via their contracts of employment.

We have procedures in place and employees trained in line with the DP Law to deal with any suspected data security breach and will notify you of a suspected breach where we are required to do so.

How long will we keep your personal data for?
Generally speaking, Source will process and store your personal data for the duration of our services or for the duration of our business relationship. Thereafter, we will store your data for as long as is necessary or required in order to fulfil legal, contractual or statutory obligations and/or in respect of the establishment, exercise or defence of legal claims and, in general where there is a legitimate reason for doing so. Details of our retention policy can be obtained on request.

What are my rights?
You have the following ten rights under The Data Protection (Bailiwick of Guernsey) Law, 2017. 

  • 1. Right to information about why personal data is collected from you. When you are asked to provide any information about yourself to us we have a legal requirement to make it clear who we are and what exactly is going to happen to your data – in legal terms this is known as ‘fair processing information’. Source provides this information above in this privacy notice.
  • 2. Right of access. This entitles you to ask what data we hold about you and why by submitting a ‘subject access request’. 
  • 3. Right to object to processing for direct marketing purposes. If we use your personal data to market products or services to you, you have the right to tell us to stop. You are able to manage this yourself by unsubscribing otherwise email or call us directly, we must stop sending you material when you ask.
  • 4. Right to object to processing on grounds of public interest. Broadly speaking, this means that if we say we are processing your personal data because it is in our ‘legitimate interests’, or in the public interest, you have the right to ask us to stop. However, we can refuse your request if we can prove our reasons outweigh your reasons for wanting us to stop. Source does not currently use any personal information in this way.
  • 5. Right to object to processing for historical or scientific purposes. If we are using your personal information for historical or scientific purposes, you have the right to ask us to stop. Source does not currently use any personal information for historical or scientific purposes.
  • 6. Right to rectification. If we have information about you that is not factually correct or accurate you have the right to ask us to correct it.
  • 7. Right to erasure. This right is sometimes called the ‘right to be forgotten’. In certain circumstances, you have the right to tell us to delete your information from our records entirely.
  • 8. Right to restriction of processing. In certain circumstances, you have the right to tell us we can only use your information for a specific purpose, or purposes.
  • 9. Right to not be subject to decisions based on automated processing. This means you have the right to ask for a human being only to make decisions about your information. This is to avoid the “computer says no” scenario whereby you may be refused a product or service solely based on an algorithm, or other automated decision-making process. Source does not currently use any form of automated processing.
  • 10. Right to data portability. This means you can ask us to remove your information from our systems and give it to you in a format that is ‘machine-readable’ so that it can be easily transported and entered into another organisation’s IT system.

Right to withdraw consent 
By applying for a role with Source and/or by registering as a candidate with Source, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact us using the details below. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.

Changes to the privacy notice 
If we change or update our privacy notice, we will post those changes on our website with links on our email signatures and all other automated communications, so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it.

If you need any advice on your rights or wish to make a complaint, please contact the supervisory authority, The Office of the Data Protection Authority on 01481 742074 or email [email protected].

Contact at Source
Should you have any questions in relation to this privacy notice, how Source processes your information or to action any of your rights under the DP Law please contact Julia Martin, Managing Director on 01481 701616 or email [email protected]

This privacy notice was last updated on 17 November 2020.